Applicant Eugene Flowers sustained an admitted industrial right shoulder injury on September 16, 2003, while working as a painter, and later alleged a psychiatric injury as a compensable consequence, which defendant disputed. Lien claimant Behavioral Medicine and Health Psychology (Dr. Vahedian) sought reimbursement for psychological treatment. The WCJ found the psyche injury industrial, the treatment reasonable and necessary, and awarded payment per OMFS plus statutory increase and interest, while disallowing medical-legal charges and rejecting defendant's section 4903.8(d) declaration defense. Defendant sought reconsideration, arguing lack of proof of treatment, untimely declaration, improper award of statutory increase/interest, and that only charges filed with the lien could be awarded. The Board, after reconsideration, affirmed the F&A, adopting the WCJ's Report and Opinion on Decision, finding the treatment was supported by QME reporting (Drs. Anselen and Nagelberg) and that pre-2013 liens lacking timely 4903.8(d) declarations are not invalidated by statute given the strong public policy favoring disposition on the merits.
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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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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