OMAR ROSAS vs. LAURENCE-HOVENIER, INC., CALIFORNIA CONTRACTORS' NETWORK administered by AMERICAN CLAIMS MANAGEMENT

This case involves a lien claim for home health care services provided to Omar Rosas. The lien claimant, Tayde Perez, contended that the services were reasonably required and that recent case law supported developing the record on the employer's receipt of a prescription. The Workers' Compensation Appeals Board denied the petition for reconsideration, adopting the WCJ's report. The WCJ found no substantial medical evidence supporting the necessity of the home health care services, and that even if the services were deemed necessary, Labor Code §4600(h) barred recovery as there was no evidence the employer received a prescription prior to 2013.