Leshen, Corrine

Lien claimant Southland Spine & Rehabilitation Medical Center sought reconsideration of a WCJ's December 18, 2025 Findings and Order that dismissed its medical treatment lien by operation of law for failing to timely file the declaration required under Labor Code section 4903.05(c)(2) by July 3, 2017. The lien, filed January 7, 2011, sought reimbursement for medical treatment under section 4903(b), and lien claimant had paid an activation fee under section 4903.06. Lien claimant argued that because its lien predated January 1, 2013 and was subject to an activation fee rather than a filing fee, the declaration requirement did not apply. The Board rejected this argument, holding that the section 4903.05(c) declaration requirement applies to all section 4903(b) medical treatment liens filed before January 1, 2017, and that failure to file timely resulted in dismissal with prejudice by operation of law. The petition for reconsideration was denied.