Miguel Velazquez — ADJ10348591, ADJ10349019

This is a Decision After Remittitur following the Third District Court of Appeal's decision in Meadowbrook Ins. Co. v. WCAB (2019) 42 Cal.App.5th 432. Lien claimant DFS Interpreting sought to recover on its lien for interpreting services despite failing to request a second review of the disputed payment amount. The WCJ originally found and the Appeals Board affirmed that the interpreter fee schedule was not subject to second review/IBR because it was not subject to Independent Bill Review. The Court of Appeal annulled that decision, holding the interpreter fee schedule was an 'applicable fee schedule' subject to IBR and the second review requirement under Labor Code section 4603.2(e). On remittitur, the Appeals Board granted reconsideration, rescinded the April 26, 2018 Findings and Order, and substituted a new decision finding DFS's bills deemed satisfied due to its failure to request second review and IBR, ordering DFS to take nothing on its lien.