What the panel ordered
Petition for reconsideration granted; final decision deferred pending further review of the merits.
LRA Interpreters, Inc. (cost petitioner) sought reconsideration of the WCJ's Findings and Order (June 12, 2025, amended June 19, 2025) regarding interpreter service fees. The WCAB granted reconsideration and deferred a final decision pending further review.
What was disputed, and how it came out
Each issue the panel decided, with the reasoning it gave. An outcome is what this panel did on this record — not a rule, and not a prediction.
The WCAB granted reconsideration to further review whether interpreter services for deposition preparation and C&R reading were properly compensated, whether the interpreter was qualified, and whether the market rate was established. The final decision is deferred pending further review.
From the decision · page 1LRA Interpreters, Inc., (cost petitioner) seeks reconsideration of the Findings and Order (F&O) issued by the workers' compensation administrative law judge (WCJ) on June 12, 2025, and amended on June 19, 2025 for a scrivener's error, wherein the WCJ found in pertinent part that: the June 7, 2023 date of service for the interpretation of the compromise and release (C&R) falls under AD Rule 9795.3(b)(2) (Cal. Code Regs., tit. 8, § 9795.3(b)(2))1 and cost petitioner was adequately compensated by defendant; the June 6, 2024 date of service for deposition preparation does not fall under AD Rule 9795.3(7)(b)(1), but under AD Rule 9795.3(b)(2); cost petitioner did not meet its burden in establishing market rate; the existing certification of the interpreter is deemed insufficient; and the billing is deemed satisfied.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
The WCJ found the interpreter's certification insufficient and that the billing was deemed satisfied; cost petitioner did not meet its burden in establishing market rate.
Favours Defendant prevailed
These findings were central to the WCJ's denial of the full amount billed by the interpreter, leading to the petition for reconsideration.
From the decision · page 1LRA Interpreters, Inc., (cost petitioner) seeks reconsideration of the Findings and Order (F&O) issued by the workers' compensation administrative law judge (WCJ) on June 12, 2025, and amended on June 19, 2025 for a scrivener's error, wherein the WCJ found in pertinent part that: the June 7, 2023 date of service for the interpretation of the compromise and release (C&R) falls under AD Rule 9795.3(b)(2) (Cal. Code Regs., tit. 8, § 9795.3(b)(2))1 and cost petitioner was adequately compensated by defendant; the June 6, 2024 date of service for deposition preparation does not fall under AD Rule 9795.3(7)(b)(1), but under AD Rule 9795.3(b)(2); cost petitioner did not meet its burden in establishing market rate; the existing certification of the interpreter is deemed insufficient; and the billing is deemed satisfied.
The panel could not determine from the record whether the interpreter's qualifications and market rate were adequately addressed, necessitating further review.
Favours neutral
This uncertainty led the panel to grant reconsideration and defer a final decision.
From the decision · page 7Based on our preliminary review of this matter, we are unable to discern if these considerations have been adequately addressed, necessitating that we issue this preliminary order granting the petition to allow us to further study the issues presented.
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Labor Code section 5909
A petition for reconsideration is deemed denied unless acted upon within 60 days from the date a trial judge transmits a case to the appeals board. Transmission is reflected in EAMS as 'Sent to Recon.' Service of the Report and Recommendation constitutes notice of transmission.
The panel determined it timely acted on the petition within 60 days of transmission, as required by section 5909(a).
From the decision · page 3Under section 5909(a), the Appeals Board must act on a petition for reconsideration within 60 days of transmission of the case to the Appeals Board. Transmission is reflected in Events in the Electronic Adjudication Management System (EAMS). Specifically, in Case Events, under Event Description is the phrase "Sent to Recon" and under Additional Information is the phrase "The case is sent to the Recon board."
AD Rule 9795.3(b); Guitron v. Santa Fe Extruders (2011) 76 Cal. Comp. Cases 228 (en banc)
Interpreter lien claimant has the burden of proving that services were reasonably required, actually provided, and that the interpreter was qualified. The fee must be reasonable as set forth in AD Rule 9795.3(b).
The panel highlighted these requirements as relevant to the review of the interpreter lien.
From the decision · page 5lien claimant has the burden of proving, among other things, that the services were reasonably
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