Bernadette Luncinski — ADJ4383952, ADJ4362592, ADJ6871086

Lien claimants Edwin Haronian, M.D. and Osteon Surgery Center sought reimbursement for medical treatment provided to applicant Bernadette Luncinski for industrial injuries to her cervical and lumbar spine, with Osteon billing for a 2012 left wrist surgery. The WCJ found the treatment reasonable and necessary based on AME Dr. Gerald Paul's March 10, 2009 report and ordered defendant to pay the billed amounts under AD Rule 9792.5.5 because defendant failed to respond to the providers' second review requests. Defendant sought reconsideration, arguing lien claimants failed to meet their burden of proving reasonableness and necessity under the MTUS, that the wrist surgery was not shown to be industrially related, and that treatment to non-industrial body parts (wrists, knees) was improper. The Board granted reconsideration and rescinded the Joint Findings and Order, finding the record insufficient to support the WCJ's findings. The Board returned the matter to the trial level for further proceedings, holding that Dr. Paul's March 10, 2009 report likely did not satisfy lien claimants' burden because it did not mention the MTUS, did not review prior records, did not diagnose a left wrist injury, and could not justify treatment rendered years earlier or seven years later.