Dorothy Garcia — ADJ11088046

Lien Claimant Premier Psychological Services sought reconsideration of a Findings and Order that barred its request for payment under Labor Code section 4603.2(b)(1)(B). Applicant Dorothy Garcia's psyche claim was denied by the carrier on 11/15/17 and later settled by Compromise and Release on 8/14/18; the claim was never found compensable. Premier rendered services from 2/28/18 through 8/13/18 but did not submit its first bill until 8/28/19, more than 12 months after the last date of service. The WCJ held the request was barred by the 12-month submission deadline, and Premier argued the statute was inoperative because the Administrative Director had not adopted rules addressing initially denied claims later found compensable. The WCAB adopted and incorporated the WCJ's report and denied reconsideration, finding the statute's plain language bars untimely requests regardless of unadopted exception rules.