Williams, Sheldon

Lien claimant Providence Holy Cross Medical Center (PHC) sought payment of its lien from the City of Los Angeles (permissibly self-insured, administered by Intercare) for medical treatment provided to applicant Sheldon Williams. The WCJ limited the lien trial to the threshold issue of whether the WCAB had jurisdiction over the lien given an express contract (between Anthem Blue Cross, PHC, and the City) fixing the amounts to be paid. The WCJ found that an express agreement existed and that, under Labor Code section 5304, the WCAB lacked jurisdiction over the lien dispute. PHC petitioned for reconsideration, which the Appeals Board denied, adopting the WCJ's report. The Board explained that disputes over the amount to be paid—whether under the official medical fee schedule or a permissible contract—are subject to independent bill review (IBR), and directed the parties to proceed with IBR. A subsequent order corrected a clerical error in the caption substituting the correct adjudication number.