WCPanelIQ
PanelMed-legalLienDenied

Doreen Erhahon — SAU10439563

DOREEN ERHAHON, Applicant vs. KAISER FOUNDATION HOSPITAL, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES, INC., Defendants

ADJ number
SAU10439563
Decision date
Jun 2, 2021
District office
San Bernardino
WCJ
William E. Gunn
Claim administrator
Sedgwick Claims Management Services, Inc.
Commissioners
—
LC §139.21LC §5313LC §5705LC §5900LC §5902LC §5903CCR §10396CCR §10843CCR §10961

Summary

Med-Legal, LLC, a copy/medical-legal services provider, sought reconsideration or removal of a WCJ's February 10, 2021 Order consolidating 57 cases (affecting 42 lien claims) for discovery purposes and staying Med-Legal's collection efforts, after Kaiser alleged a pattern of fraudulent billing and that Med-Legal had obstructed discovery by dismissing or forfeiting individual bills. The WCAB held that the Consolidation Order is an interlocutory, procedural, non-final order that did not determine any substantive right or liability, so reconsideration was improper. The Board denied removal because Med-Legal showed no substantial prejudice or irreparable harm—it could still operate, file/amend liens, and use the non-IBR process—and because reconsideration remains available if a final order issues. The Board found no due process violation since Med-Legal received notice and filed an opposition that was considered. The Consolidation Order was affirmed and the Petition for Removal denied.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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