Aragon-Zarate, Edgar

Lien claimant Joyce Altman Interpreting provided Spanish interpreting services during applicant's medical treatment appointments and filed a lien on June 27, 2017, declaring under Labor Code section 4903.05(c)(1)(G) that it was 'a certified interpreter rendering services during a medical-legal examination, a copy service providing medical-legal services, or has an expense allowed as a lien under rules adopted by the administrative director.' The WCJ found this declaration false or inaccurate because the interpreting was provided in connection with medical treatment, not medical-legal services, and dismissed all three liens. The WCAB granted reconsideration and held the record was unclear as to whether all three claims were denied at the time services were rendered, which bears on whether the lien should instead have been declared under subdivision (c)(1)(E) (neglected or unreasonably refused medical treatment). Recognizing that interpreting at medical treatment appointments is an integral component of medical treatment under section 4600(g), and that relief from dismissal may be available under CCP section 473(b) for mistake or excusable neglect, the Board rescinded the F&O and returned the matter to the trial level for development of the record.