PanelQMELienGranted
Lopez, Olga
OLGA LOPEZ, Applicant vs. VILLA TEPEYAC; PREFERRED EMPLOYERS INSURANCE COMPANY, Defendants
- ADJ number
- ADJ13324858
- Decision date
- Nov 30, 2025
- District office
- Los Angeles
- WCJ
- —
- Claim administrator
- Preferred Employers Insurance Company
- Commissioners
- JOSEPH V. CAPURRO, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, PAUL F. KELLY, COMMISSIONER
Injury / body parts: neck, wrists, arms, back, shoulders, upper extremities, lower extremities, internal organs, psyche, nervous system, abdomen/gastritis, knee, hips, ankle, thoracic spine, lumbar spine
LC §5909LC §5900LC §4610LC §4062LC §5402LC §4622CCR §10964CCR §10600CCR §9792.9
Summary
Lien claimant Dr. Jonathan Kohan sought reconsideration of a September 11, 2025 F&O that disallowed his lien on the ground that no qualifying RFA had been submitted, rendering all related lien issues (UR, bill review, penalties/interest) moot. Defendant had denied both cumulative trauma claims on December 15, 2020, and issued a Notice of Deferral of Medical Treatment Requests on June 6, 2022, deferring UR until liability was determined. The case-in-chief settled by Compromise and Release in October 2022 with liability for industrial injury still expressly in dispute. The WCAB found that liability was not actually determined until the WCJ's September 11, 2025 findings of industrial causation, triggering the employer's obligation to conduct retrospective UR under Labor Code section 4610(l)(m) and CCR 9792.9(b)(2). The Board granted reconsideration, preserved unchallenged Findings #1 and #2 (industrial injury), rescinded the F&O, and remanded for adjudication of all remaining lien issues.
Issues
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Holding
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Analysis
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Applicant takeaway
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Defense takeaway
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Provider takeaway
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