Escalante, Emidio

Lien claimant Citywide Scanning Service, Inc. sought reconsideration of a WCJ's F&O that limited its medical-legal copy service reimbursement to 50% of the fee schedule and invalidated subpoenas issued before May 27, 2015. The dispute centered on whether a contested claim existed when the copy services were performed, whether the subpoenas were validly served, and whether applicant was required to demand records before subpoenaing them. The Board found the WCJ misconstrued the claims: defendant only accepted liability for the back in the specific injury claim and denied the cumulative trauma claim, so contested claims existed as early as October 1, 2014, and certainly when Applications were filed alleging disagreement over 'ALL BENEFITS.' The Board rescinded the F&O and substituted findings that a contested claim existed, that services were reasonable and necessary, and that the lien claimant is entitled to payment, while deferring the amount and returning the matter to the trial level.