Escobar, Salvador

Salvador Escobar sustained industrial bilateral carpal tunnel syndrome on January 19, 2017, and his case-in-chief was resolved by Compromise and Release for $15,000. Lien claimant Joyce Altman Interpreting sought reimbursement for Spanish-language interpreting services allegedly provided at numerous medical and acupuncture appointments. The WCJ disallowed the lien, finding the lien claimant failed to prove the services were actually provided, that applicant actually received treatment, and that the services were reasonable and necessary. On reconsideration, the Board found the WCJ erred in excluding Exhibit One for lack of authentication of applicant's signature (since no doubt about the signature was raised), but nevertheless affirmed because applicant told PQME Dr. Sofia he had received no treatment of any kind, contradicting the billed services. The Board concluded the lien claimant failed to meet its burden of proving the interpreting services were reasonably and necessarily incurred.