Fernandez, Patrick

Lien claimant Reliable Medical Supply sought reconsideration of a June 2025 Findings and Order in which the WCJ found applicant Patrick Fernandez sustained an industrial injury to his chest, back, and leg in a 2002 motor vehicle accident but disallowed the lien for medical supplies (an interferential unit and heating pad) for failure to prove medical necessity. The Appeals Board granted reconsideration, finding on preliminary review that the lien claimant may have actually met its burden of proof through submitted medical reports, prescriptions, and billing, especially since defendant presented no rebuttal evidence or utilization review. The Board also noted the WCJ failed to rule on the admissibility of several exhibits marked for identification and failed to resolve threshold issues including the statute of limitations and whether the lien was resolved by global settlement. The Board granted reconsideration to study the record further and deferred a final decision after reconsideration.