Juan Chavez — ADJ8914656

Lien claimant Paul Schroeder, D.C., applicant Juan Chavez's primary treater, sought recovery on a $1,205.43 medical treatment lien (inclusive of penalties and interest) against Star Insurance Company, administered by Illinois Midwest Insurance Agency. Defendant argued the WCAB lacked jurisdiction because a 'chain of contracts' existed between Illinois Midwest, MedRisk, and Schroeder, and because the provider allegedly failed to comply with second bill review procedures. The WCJ found defendant offered no evidence that the MedRisk contract actually controlled the rates for treating this applicant, that the treatment's reasonableness and necessity were undisputed, and that defendant failed to prove timely EORs were issued for most dates of service. The Board granted reconsideration to amend Finding of Fact No. 2 and the Order to exclude charges for the 10/10/2018 date of service (for failure to timely request second bill review) and to credit an amount not to exceed $545.77 already paid, otherwise affirming the award subject to the Official Medical Fee Schedule.