Ortiz, Jaime

Three lien claimants (Reinherz Chiropractic, Tariq Mirza, M.D., and Mario Corzo Interpreting) sought reconsideration of a March 4, 2021 Joint Findings of Fact and Order arising from two consolidated claims of an auto body worker who sustained industrial injuries to his bilateral knees and right shoulder, resolved by Compromise and Release in 2014. The WCJ allowed Reinherz's chiropractic lien for 24 visits before and 24 visits after applicant's June 1, 2006 surgery under Labor Code section 4604.5, disallowed Dr. Mirza's lien for failure to prove medical necessity, and disallowed Corzo's interpreting lien for lack of evidence of certification or provisional certification. The Board affirmed the rulings on Reinherz and Mirza, finding no persuasive legal challenge to the WCJ's application of section 4604.5 or the MTUS presumption. However, the Board amended the order to defer the Corzo interpreting lien and remanded that issue because it was unclear whether the WCJ fully applied the analysis from Guitron v. Santa Fe Extruders regarding provisional certification. The matter was returned to the trial level for further proceedings consistent with Guitron.