CompFox AI Summary
The Appeals Board granted reconsideration and returned the case to the trial level for further proceedings concerning a lien claimant's reimbursement. The Board found the administrative law judge erred in denying the lien solely due to a lack of formal document authentication, as workers' compensation proceedings are not bound by strict common law evidence rules. Furthermore, the Board clarified that lien claimants bear the burden of proving the reasonableness of outpatient surgery fees, as detailed in their recent en banc decision, Tapia.
Full Decision Text1 Pages
The Appeals Board granted reconsideration and returned the case to the trial level for further proceedings concerning a lien claimant's reimbursement. The Board found the administrative law judge erred in denying the lien solely due to a lack of formal document authentication, as workers' compensation proceedings are not bound by strict common law evidence rules. Furthermore, the Board clarified that lien claimants bear the burden of proving the reasonableness of outpatient surgery fees, as detailed in their recent en banc decision, Tapia.
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