Maria Isabel Guerrero — ADJ21274145, ADJ21274168

Lien claimant Medland Medical sought reconsideration of a WCJ's Findings and Order that denied payment for a September 15, 2025 'Primary Treating Physician's Comprehensive Medical-Legal Report' by Dr. Haghighinia, on grounds the lien claimant failed to prove the services were medical-legal. The WCJ had concluded the report was not substantial evidence of causation because it failed to discuss how the admitted November 24, 2024 specific injury interacted with the claimed cumulative trauma. The Appeals Board granted reconsideration, holding that substantial evidence is not the standard for payment of a medical-legal report; the proper test is whether a contested claim existed, whether the report was obtained to prove or disprove that claim, and whether it was reasonable and necessary when incurred. Because the report issued after defendant's August 8, 2025 denial of applicant's claim and was intended to prove the disputed cumulative injury, lien claimant met its burden. The Board rescinded the F&O and awarded Medland Medical $2,299.34 (the OMFS amount) plus interest and penalties, deferring costs, attorney's fees, and sanctions.