Darnella Scott Street — ADJ7390255

Applicant Darnella Scott Street sustained a left knee injury on January 19, 2010 while employed by BART, and underwent total knee replacement surgery in 2015. Lien claimant Electronic Waveform Labs (EWL) sought payment for an H-Wave stimulator unit provided to applicant after surgery and during physical therapy. BART, permissibly self-insured and administered by Athens Administrators, contested the lien, arguing EWL had not met its burden to prove the H-Wave unit was reasonably required and that the supporting documentation was not substantial medical evidence. The WCJ found EWL met its burden, relying on the treating physician's PR-2 equivalent reports, physical therapy notes showing applicant felt more relief with the H-Wave than TENS, and the AME's opinion endorsing interferential stimulation as superior to TENS. The WCAB adopted and incorporated the WCJ's report and denied reconsideration.