ADJ4457963 · July 20, 2026

The Appeals Board found the September 20, 2003 report of Dr. Goalwin was legally obtained under section 4060 as it existed in 2003, based on the report's statements that it was requested by applicant's counsel and addressed contested medical issues, making the lien reimbursable with statutory increase and interest.

From the decision · page 92. The September 20, 2003 report of Julie Goalwin, Ph.D., was a legally obtained medical- legal report pursuant to section 4060 as it existed in 2003. 3. The ML-103 charges of Angoal Medical are subject to statutory increase and statutory interest under Labor Code sections 4622 and 5800, respectively. 4. Angoal Medical Collections is entitled to reimbursement of the filing fee, having demonstrated liability for the charges.

The September 20, 2003 report of Dr. Goalwin states it was requested by applicant's attorney and addresses contested medical issues relevant to the claim.

Favours Applicant prevailed

This fact supports the finding that the medical-legal report was legally obtained under Labor Code section 4060, making the lien reimbursable.

From the decision · page 7(ODAR, at pp. 5-6.) Our ODAR thus returned the matter to the trial level to allow the parties to submit evidence responsive to the issue of the circumstances under which the report of Dr. Goalwin was obtained. Because neither party offered any additional evidence, the WCJ reasonably concluded that lien claimant had not met its burden of establishing that the requirements described in section 4060(c) were met, and ordered the lien disallowed as a result. However, following our complete review of the entire evidentiary record in this matter as occasioned by lien claimant’s Petition, we are persuaded that the evidence is sufficient to support a finding that the September 20, 2003 was a validly obtained and admissible report under section 4060 as it existed in 2003. As is noted above, there is no dispute that the report substantively addresses a contested claim as contemplated by section 4620(a). The report itself states that “[t]he reason for the referral is based on the claim that the patient is experiencing emotional consequences due to workplace trauma,” and that the report “will render opinions concerning specific referral questions with respect to the need for psychiatric-psychological diagnosis, psychotherapy, apportionment, and disputed medical facts.” (Ex. 12, Report of Julie Goalwin, Ph.D., dated September 20, 2003, at p.

Issued a psychiatric qualified medical-legal evaluation report on September 20, 2003, addressing contested psychiatric injury and occupational stress injury effects, requested by applicant's counsel.

The report itself states it was generated at the request of applicant's counsel and addresses contested medical issues relevant to the claim.

Labor Code section 4622

Labor Code section 4622 provides for statutory increase on reimbursable medical-legal expenses.

The Board ordered statutory increase on the lien reimbursement under section 4622.

From the decision · page 92. The September 20, 2003 report of Julie Goalwin, Ph.D., was a legally obtained medical- legal report pursuant to section 4060 as it existed in 2003. 3. The ML-103 charges of Angoal Medical are subject to statutory increase and statutory interest under Labor Code sections 4622 and 5800, respectively. 4. Angoal Medical Collections is entitled to reimbursement of the filing fee, having demonstrated liability for the charges.

Labor Code section 4060

Labor Code section 4060 (2003) governs the admissibility and liability for medical-legal reporting in workers’ compensation proceedings.

The Board applied section 4060 to determine the validity of the medical-legal report and lien reimbursement.

From the decision · page 6Defendant avers, however, that lien claimant has not met its burden of establishing compliance with section 4060 as it existed in 2003, governing the admissibility of and liability for medical-legal reporting in workers’ compensation proceedings. The 2003 statute provided, in relevant part:

Labor Code section 4620

Labor Code section 4620 defines medical-legal expenses and contested claims for workers’ compensation.

The Board applied section 4620 to establish that the report addressed a contested claim and was a medical-legal expense.

From the decision · page 5As relevant to these proceedings, the issue framed for decision by the parties at the December 11, 2020 lien trial was whether Dr. Goalwin’s September 20, 2003 report was “a proper medical legal report.” (Minutes of Hearing, dated December 11, 2020, at p. 2:24.) Section 4620(a) defines a medical-legal expense as a cost or expense that a party incurs “for the purpose of proving or disproving a contested claim.” (Lab. Code, § 4620(a).) Lien claimant’s initial burden in proving entitlement to reimbursement for a medical-legal expense is to show that a “contested claim” existed at the time the service was performed. Section 4620(b) sets forth the parameters for determining whether a contested claim existed. (Lab.

Labor Code section 5800

Labor Code section 5800 provides for statutory interest on reimbursable medical-legal expenses.

The Board ordered statutory interest on the lien reimbursement under section 5800.

From the decision · page 92. The September 20, 2003 report of Julie Goalwin, Ph.D., was a legally obtained medical- legal report pursuant to section 4060 as it existed in 2003. 3. The ML-103 charges of Angoal Medical are subject to statutory increase and statutory interest under Labor Code sections 4622 and 5800, respectively. 4. Angoal Medical Collections is entitled to reimbursement of the filing fee, having demonstrated liability for the charges.

The September 20, 2003 report of Dr. Goalwin states it was requested by applicant's attorney and addresses contested medical issues, supporting the validity of the medical-legal report.

From the decision · page 7(ODAR, at pp. 5-6.) Our ODAR thus returned the matter to the trial level to allow the parties to submit evidence responsive to the issue of the circumstances under which the report of Dr. Goalwin was obtained. Because neither party offered any additional evidence, the WCJ reasonably concluded that lien claimant had not met its burden of establishing that the requirements described in section 4060(c) were met, and ordered the lien disallowed as a result. However, following our complete review of the entire evidentiary record in this matter as occasioned by lien claimant’s Petition, we are persuaded that the evidence is sufficient to support a finding that the September 20, 2003 was a validly obtained and admissible report under section 4060 as it existed in 2003. As is noted above, there is no dispute that the report substantively addresses a contested claim as contemplated by section 4620(a). The report itself states that “[t]he reason for the referral is based on the claim that the patient is experiencing emotional consequences due to workplace trauma,” and that the report “will render opinions concerning specific referral questions with respect to the need for psychiatric-psychological diagnosis, psychotherapy, apportionment, and disputed medical facts.” (Ex. 12, Report of Julie Goalwin, Ph.D., dated September 20, 2003, at p.