CARLOS CARTAGENA vs. ORION ORNAMENTAL IRON, INC.; CYPRESS INSURANCE COMPANY

The Workers' Compensation Appeals Board (WCAB) denied the Petition for Reconsideration filed by Cypress Insurance Company. The petition challenged a Findings and Order from November 26, 2024, which found in favor of a lien claimant, DENTAL TRAUMA CENTER. The defendant argued that the lien claimant failed to timely submit billing and that there was insufficient evidence for the dental injury. Additionally, the defendant sought retrospective utilization review. The WCAB, adopting the WCJ's report, upheld the original decision, citing that the lien claimant's billing was timely served on a co-defendant, that exceptions to the 12-month billing rule apply when a claim is initially denied as non-industrial, and that the defendant failed to present medical evidence to rebut the applicant's medical opinions. The WCAB also denied retrospective utilization review due to the defendant's initial failure to medically investigate the disputed body part.