have been received;'
referred of prescribed by "physicians"
at an outpatient surgical facility;
surgery facility fees, however, such
fees nevertheless must be 'reasonable';
and
the Board may take into consideration
a number of factors, including but not
limited to the following: the medical
provider's usual fee and the usual fee
of other providers in the same
geographical area, which means the
fee usually accepted, not the fee
usually charged."
Appeals Board (Board) has issued
an en banc decision that should
have far reaching effect upon
medical treatment liens.
PATTERSON
FLOOR
COVERINGS
industrial left knee injury. The
applicant had left knee surgery at an
outpatient surgery center. The center
billed the defendant for three
procedures using CPT codes. The
defendant sent the billing to a
review service.
to the provider indicating what it
rate for the procedures in the providers
area.
Compensation Judge (WCJ)
disallowed the remaining balance on
the lien, the WCJ indicated the lien
claimant failed to establish their case.
failure to specifically object to a
medical treatment lien claim on the
basis of reasonable medical necessity
(or on any other basis) does not effect a
waiver of that objection;
not apply unless the prerequisites to the
section's application have been met,
i.e., the medical treatment in question
must have been 'provided or authorized
by the treating physician selected by
the employee or designated by the
employer (pursuant to section 4600)'
and the medical provider's billing to the
defendant must have been 'properly
documented' with an 'itemized billing,
together with any require reports and
any written
Valenzuela, Brown
Editor: Harvey Brown
Address: 441 Old Newport Blvd
105 Newport Beach, CA 92663
Phone: 949 574-7835
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