Crisanto Francisco — ADJ8456534, ADJ8456532

Applicant Crisanto Francisco, a farm laborer, sustained accepted injuries to his neck and back while working for Ocean Breeze International. Lien claimant Specialty Care Clinic served as primary treating physician and provided exams/reports as well as physical therapy and acupuncture, while Joyce Altman Interpreters provided interpreting services. The WCJ disallowed all charges for physical therapy and acupuncture because the lien claimant failed to prove that Requests for Authorization (RFAs) were actually served on defendant, and disallowed charges for non-accepted body parts, but allowed charges for exams/reports relating to the cervical and lumbar spine plus corresponding interpreting services. Defendant petitioned for reconsideration, arguing the court erred by not requiring the lien claimant to prove RFAs were made relative to office visits and reports. The WCAB denied reconsideration, adopting the WCJ's reasoning that there is no requirement for a treating physician to submit an RFA simply to examine his own patient and prepare a report, as opposed to requesting a specific course of treatment.