WCPanelIQ
PanelMed-legalLienGranted in Part

Janette Garcia — ADJ11186589

JANETTE GARCIA, Applicant vs. FINE HOME HEALTH, INC.; NORGUARD INSURANCE COMPANY; administered by GUARD INSURANCE, Defendants

ADJ number
ADJ11186589
Decision date
Jun 17, 2026
District office
Los Angeles
WCJ
—
Claim administrator
Guard Insurance (administering NorGuard Insurance Company)
Commissioners
JOSÉ H. RAZO, COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER, ANNE SCHMITZ, DEPUTY COMMISSIONER

Injury / body parts: neck, back, right arm, right wrist, waist, shoulders, body systems

LC §3205.5LC §4600LC §4620LC §4621LC §4622LC §4903LC §5402LC §5705.5

Summary

Lien claimant Ameri Chiropractic sought reconsideration of a WCJ's F&O finding that applicant did not sustain injury AOE/COE and that defendant was not liable for self-procured medical treatment or the lien. The Board affirmed the finding that defendant is not liable for self-procured treatment because the lien claimant's billing showed the first treatment date (February 1, 2018) occurred two days after the denial (January 30, 2018), and the January 18, 2018 report was neither served nor charged. However, the Board found the WCJ erred by failing to address whether the lien claimant was entitled to payment as a medical-legal expense under sections 4620, 4621, and 4622. The Board amended the F&O to defer the medical-legal expense issue so it could be adjudicated in the first instance, noting that the January 30, 2018 denial letter likely established a contested claim. The decision affirmed the F&O as amended.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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