Kent Sath — ADJ11637452, ADJ11681891, ADJ12252942

Riverside Community Hospital, a lien claimant, sought reconsideration of a December 2, 2022 Findings and Order disallowing its lien for emergency services provided to applicant Kent Sath following a July 22, 2017 work injury. The hospital billed $218,390.00 but received only $29,993.79, which the WCJ found to be the reasonable value of the services. The lien claimant argued that emergency services are excluded from the OMFS because the OMFS is essentially Medicare's prospective payment system (PPS), that a pre-2003 version of the OMFS should apply, and that emergency liens should be paid at contract rates under Section 5307.11. The WCAB rejected all three arguments, finding the OMFS was not adopted as the PPS, that Section 5307.1(e)(1) never applied because the AD adopted a fee schedule effective January 1, 2004, and that Section 5307.11 requires an actual contract for non-OMFS payment. The petition was denied.