Lien claimants (Comprehensive Outpatient Surgery Center, California Urgent Care Center, Technical Surgery Support, and Marina Russman, M.D.) sought reconsideration of a WCJ's Findings and Orders that disallowed liens related to seven lumbar epidural steroid injections provided to applicant Tadesse Senbetu, a CNA for the County of Los Angeles, for a cumulative trauma injury. The WCJ found the lien claimants failed to prove that the injection-related services were consistent with the Medical Treatment Utilization Schedule (MTUS), since defendant largely never sent the requests through Utilization Review (UR), shifting the burden of proof to the lien claimants under Dubon. The Board adopted and incorporated the WCJ's Report and Opinion on Decision, holding that the lien claimants did not meet their burden of proof by a preponderance of evidence. Dr. Russman's non-injection services (office visits, reports, blood tests) were found reasonable and valued at $1,353.92 less a credit. The Petition for Reconsideration was denied.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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Defense takeaway
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Provider takeaway
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Similar decisions
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