WCPanelIQ
PanelLienDenied

Abraham Christian — ADJ3920506, ADJ4316583

ABRAHAM CHRISTIAN, Applicant vs. WESTPORT INSURANCE CORP. for RING SECURITY AGENCY, INC., administered by GALLAGHER BASSETT, Defendants

ADJ number
ADJ3920506, ADJ4316583
Decision date
May 9, 2021
District office
Salinas
WCJ
Roisilin Riley
Claim administrator
Gallagher Bassett
Commissioners
—

Injury / body parts: knees, back, digestive, neck, psyche, internal, dental, sleep, sexual dysfunction, eyes, hypertension, TMJ

LC §4603.2

Summary

Lien claimant Dental Trauma Center (DTC) provided dental services to applicant Abraham Christian from 2009 through 2013 in connection with two industrial injury claims. After the claims were resolved by Compromise and Release, the lien was tried and DTC was ordered paid $27,567.89, less prior payments, with no interest or penalty ordered. DTC petitioned for reconsideration, contesting only the failure to award penalty and interest under Labor Code section 4603.2(b). The WCAB denied reconsideration, adopting the WCJ's report which found most services were dental codes not included in the OMFS (requiring DTC to establish reasonable charges), that defendant had issued EOBs with reason codes for the contested amounts, and that DTC failed to specify which EOBs were late or pursue secondary review.

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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