Victoria Escobar — ADJ10790437

Applicant Victoria Escobar, a charge nurse, claimed cumulative injury (2011-2016) including a dental injury. After her psychiatric claim was denied in 2016, her PTP Dr. Stokes repeatedly requested authorization for a dental specialist due to teeth grinding/bruxism, and lien claimant The Dental Trauma Center (Dr. Schames) examined her on January 9, 2018. The WCAB, in its ODAR, found applicant sustained an industrial dental injury based on Dr. Schames' substantial medical reporting, that lien claimant met its burdens under Labor Code sections 4620, 4621, and 4622, and deferred the amounts owed. Defendant sought reconsideration arguing the PTP failed to incorporate Dr. Schames' reports, the reports were not substantial evidence, the deferral was error, and the lien was procedurally invalid. The Board denied reconsideration, finding substantial medical evidence supported industrial causation under the contributing-cause standard and that medical treatment is not subject to apportionment.