What the panel ordered
The January 27, 2021 Findings and Order is rescinded and substituted with a new Findings and Order finding that a contested claim existed at the time services were rendered; the expenses were necessary to prove a contested claim; the services were reasonable and necessary; and lien claimant is entitled to payment under Labor Code section 4622. The issue of the amount of payment, including interest, costs, and penalties, is deferred to the WCJ.
Decision After Reconsideration issued by the Workers' Compensation Appeals Board on June 6, 2025, rescinding the January 27, 2021 Findings and Order and substituting a new Findings and Order.
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 Board found that a contested claim existed at the time the services were rendered, the expenses were necessary to prove the contested claim, and the services were reasonable and necessary. Therefore, the lien claimant is entitled to payment under Labor Code section 4622, but the amount of payment is deferred to the WCJ.
From the decision · page 6Accordingly, we rescind the F&O and substitute a new F&O that finds that a contested claim existed at the time services were rendered; that the expenses were necessary to prove a contested claim; that the services were reasonable and necessary; and that lien claimant is entitled to payment under section 4622. We award payment, but we defer the issue of the amount of the payment and return the matter to the WCJ to determine the amount of payment, including interest, costs, and penalties.