Myers, Jay

Lien claimant Tiare Brock sought reconsideration of a June 4, 2025 Findings and Order in which the WCJ disallowed Brock's $13,150 lien on the basis that the lien claimant failed to provide evidence that any request for authorization (RFA) was served on defendant, rendering the lien deficient under Labor Code section 4610 and 8 CCR § 9792.6.1(t). The applicant, a Sheriff Deputy Sergeant, had sustained industrial injury to his skin, psyche and PTSD over a 1994-2019 cumulative period, and the underlying case had resolved by stipulation. Brock argued the WCJ improperly elevated a procedural formality (the RFA requirement) over the substantive mandate of section 4600 to provide reasonable and necessary medical care. The Appeals Board granted reconsideration, finding it was not persuaded the record was properly developed or supported by substantial evidence. The Board deferred a final decision pending further review of the merits and the entire record.