OTTO BAUTISTA vs. PREFERRED WINDOW PRODUCTS, INC., BERKSHIRE HATHAWAY

The Workers' Compensation Appeals Board (WCAB) granted reconsideration to a lien claimant whose due process rights were affected by a prior finding. The original finding stated the applicant must treat within the employer's Medical Provider Network (MPN) for the employer to be liable for treatment. The WCAB amended this finding to clarify that while treatment must occur within the MPN, liability for past treatment provided outside the MPN is reserved for a future lien conference or trial. This amendment ensures the lien claimant's right to litigate their claim is preserved.