Gerardo Perez — ADJ10496049, ADJ6613623

Defendant and lien claimant California Imaging Solutions (CIS) sought reconsideration of a July 26, 2021 Joint Findings, Award and Order in which the WCJ found CIS entitled to reimbursement on its copy-service lien (medical-legal in nature) and disallowed the liens of Comprehensive Outpatient Surgery Center and Technical Surgery Support. Defendant argued the lien of Dental Trauma Center should also be disallowed consistent with the WCJ's finding that applicant suffered no dental injury, and that CIS's services were not reasonable or necessary. The Board found the issues regarding CIS's lien were never clearly defined and that Finding of Fact 7 ('reasonably necessary medical-legal services') was ambiguous and unsupported by record citations, deviating from Labor Code section 4621(a). The Board granted reconsideration, amended the decision to disallow the Dental Trauma Center lien, rescinded the award, and deferred the reasonableness and necessity issues regarding CIS to the trial level with jurisdiction reserved. The Board emphasized that for pre-July 1, 2015 copy services there is no applicable fee schedule and provided guidance under Colamonico and Kunz.