CompFox AI Summary
The Workers' Compensation Appeals Board denied Tri County Medical Group's (TCMG) petition for reconsideration of a finding that its lien claim was barred by the 18-month limitation in Labor Code section 4903.5(a). The Board majority held that because TCMG's last date of service was January 29, 2015, after the July 1, 2013 effective date for the shorter period, the 18-month limit applied. TCMG's lien was filed over 18 months after this last date of service and was therefore untimely. A dissenting commissioner argued that for continuously provided services crossing the July 1, 2013 date, the three-year limit should apply to avoid requiring multiple lien filings.
Full Decision Text1 Pages
The Workers' Compensation Appeals Board denied Tri County Medical Group's (TCMG) petition for reconsideration of a finding that its lien claim was barred by the 18-month limitation in Labor Code section 4903.5(a). The Board majority held that because TCMG's last date of service was January 29, 2015, after the July 1, 2013 effective date for the shorter period, the 18-month limit applied. TCMG's lien was filed over 18 months after this last date of service and was therefore untimely. A dissenting commissioner argued that for continuously provided services crossing the July 1, 2013 date, the three-year limit should apply to avoid requiring multiple lien filings.
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