Richard Chavez — ADJ10159304

Lien claimant Premier Psychological Services sought reconsideration of a WCJ's Findings and Award that found it waived its right to reimbursement for medical-legal services by failing to properly submit its billing, but awarded a reduced 'equitable' amount of $2,830.00 without interest or penalties. Applicant, a truck driver, sustained industrial injury to his lumbar spine and hernia; his treating psychologist Dr. Michaels performed a psychological medical-legal evaluation after a claimed psyche injury was contested. The Board granted reconsideration, holding that a medical-legal lien accompanied by a billing statement filed under section 4903(b) was sufficient to initiate the section 4622 dispute resolution process, and that defendant's failure to issue a timely EOR waived all objections except compliance with sections 4620 and 4621. The Board rejected the WCJ's reliance on UR/IMR concepts and equitable reimbursement, finding lien recovery is controlled by the Labor Code. The Board rescinded the F&A and awarded the full $8,030.00 lien amount plus statutory increase, interest from February 28, 2024, and reimbursement of the lien filing fee.