Todd Perruccio — ADJ16164777

Lien claimant Premier Psychological Services sought reconsideration of a WCA's June 20, 2025 Findings and Order that denied reimbursement of its lien for a treating physician's psychiatric report. The WCA reasoned that because Dr. Michaels' report was served June 30, 2024—ten days after the June 20, 2024 Compromise and Release was approved—there was no longer a contested issue to prove or disprove, so it did not qualify as a proper medical-legal report. The Appeals Board first found the petition timely (addressing both the amended section 5909 transmission notice rules and the extended filing deadline due to out-of-state service) and accepted the emailed petition as timely filed. On the merits, the Board found the WCA did not follow the proper analysis, holding there is no legal basis for denying reimbursement solely based on the timing of service of the report. The Board granted reconsideration and deferred a final decision pending further review, noting development of the record may be needed.