Delgado, Alicia

Defendant State Compensation Insurance Fund sought reconsideration of a February 22, 2021 F&A in which the WCJ found applicant's claimed cumulative injury compensable under the section 5402 presumption and awarded Angoal Medical Collections reimbursement at ML-103 rates plus statutory increase and interest under section 4622 for a 2003 psychiatric medical-legal report by Julie Goalwin, M.D. The Board agreed the Angoal lien was not barred under section 4903.8, upholding the validity of the 4903.8(d) declaration and the assignment despite late service, because section 4903.8(e)'s invalidity remedy applies only to liens filed on or after January 1, 2013, while this lien was filed in 2003. However, the Board found the record inadequate to determine whether Dr. Goalwin was validly selected under section 4060(c) as it existed in 2003 and could not assess the reasonableness of the charges because no specific dollar amounts were awarded. The Board rescinded and restated the F&A, deferring the selection-validity, reasonableness, statutory increase/interest, and filing-fee issues, and returned the matter to the trial level for development of the record.