Jim Neely — ADJ225564

The WCAB denied defendant County of Sacramento's petition for reconsideration of a WCJ order directing a medical billing dispute to Independent Bill Review (IBR). Lien claimant Center for Interdisciplinary Spine provided functional restoration services to applicant from December 2017 through February 2019, and defendant objected to the billings on grounds that CPT code 97799 was invalid and charges exceeded the OMFS. The WCJ found that because the sole remaining dispute concerned the reasonableness of charges and proper CPT coding, the matter was subject to the mandatory IBR process under Labor Code sections 4603.3 and 4603.6, citing the Appeals Board's decision in Senquiz v. City of Fremont. The Board adopted the WCJ's reasoning that disputes over proper CPT codes and amounts due under the OMFS fall within IBR's jurisdiction, not the WCAB's.