What the panel ordered
Denied the global and supplemental petitions appealing the Administrative Director's Medical Provider Network Determination dated September 16, 2025
Appeal from the Administrative Director of the Division of Workers' Compensation's Medical Provider Network Determination dated September 16, 2025
What was disputed, and how it came out
Each issue the panel decided, with the reasoning it gave. An outcome is what this panel did on this record — not a rule, and not a prediction.
The Board found SCIF's MPN ancillary roster valid under the applicable Labor Code and regulations, rejecting the lien claimant's argument that interpreter certification/license numbers must be publicly listed. The Board deferred the payment entitlement issue to the trial level for adjudication.
From the decision · page 7Lien claimant claims that SCIF's MPN roster violates section 4616(a)(4)(A)(i) and AD
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
SCIF's MPN ancillary roster listed entities with name, address, and telephone number but did not list individual interpreter certification/license numbers.
Favours Defendant prevailed
The Board found this compliant with Labor Code section 4616(a)(4)(A)(i) which requires listing of entity information if the service is provided by an entity rather than an individual.
From the decision · page 8We note that the 2025 Determination Letter concludes that "DWC's independent review of the MPN Provider Directory search results and Roster of Participating Providers confirmed compliance with the Labor Code. The MPN listed interpreters with their individual or entity name, physical address, and telephone number." (ADJ8112676 (Chang) Exhibit E, MPN Determination Letter dated September 16, 2025, filed September 29, 2025 and October 8, 2025.) However, even if this was not true, and the MPN roster only provided, as lien claimant alleges, interpreting entities as opposed to individual interpreters, we note that section 4616(a)(4)(A)(i) states that if "the ancillary service is provided by an entity rather than an individual, then that entity's name, address, and telephone number shall be listed." Hence, we see no violation of the statute.
Section 4616(a)(4)(A)(i) and AD Rule 9767.3(c)(3) apply to MPN application approval and publication requirements differently; the six-column requirement applies to the application, not to internet publication.
Favours Defendant prevailed
This distinction supported the Board's conclusion that SCIF's MPN ancillary roster met legal requirements despite lien claimant's objections.
From the decision · page 8Furthermore, we agree that the six-column requirement provided in AD Rule 9767.3(c)(3) applies to the application for the approval of an MPN and is not a requirement for what information must be published on the internet. (ADJ8112676 (Chang) Exhibit E, MPN Determination Letter dated September 16, 2025, filed September 29, 2025 and October 8, 2025.) Section 4616(a)(4)(A)(i) delineates what must be published on the MPN's internet website. AD Rule 9767.3(c)(3) is in the context of an application for MPN approval.
There is no legal authority requiring interpreter certification information to be made public on the MPN website.
Favours Defendant prevailed
This absence of authority supported the Board's finding that SCIF's MPN was valid despite lien claimant's claims.
From the decision · page 8Lastly, while section 5811 and AD Rule 9795.1.6 set forth the requirements for a certified interpreter, we have found no legal authority requiring information regarding an interpreter's certification be made public. AD Rule 9767.3(c)(3) requires a service provider to affirm that the providers in its MPN are properly certified; it does not require information regarding certification be public.
Section 4616(a)(4)(A)(i) became applicable starting July 1, 2021, and there was no requirement to publish an MPN roster on the internet before then.
Favours Defendant prevailed
This temporal limitation led the Board to defer payment entitlement issues for services from 2011 to 2022 to the trial level.
From the decision · page 8While we conclude that SCIF's MPN with respect to interpretation services is valid, we note that section 4616(a)(4)(A)(i) is applicable starting July 1, 2021, and that there was no requirement before then to publish an MPN roster on the internet. (§ 4616(a)(4)(A)(i).) We also note that lien claimant received a letter dated October 1, 2015 reminding it that effective November 1, 2015, SCIF required that all interpretation services be provided by Cypress Care or One Call
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
WCAB Rule 10560 (Cal. Code Regs., tit. 8, 10560(a))
WCAB Rule 10560 provides that any aggrieved party may appeal or seek to enforce an order issued by the Division of Workers' Compensation Administrative Director by filing a petition and an Application for Adjudication of Claim if one has not already been filed.
Applied to support the procedure for appealing the Administrative Director's MPN determination.
From the decision · page 4a petition, and an Application for Adjudication of Claim if one has not already been filed." (Cal. Code Regs., tit. 8, § 10560(a).)
Cal. Code Regs., tit. 8, 9767.3(c)(3)
AD Rule 9767.3(c)(3) requires that an ancillary service provider file have six specific columns including name, specialty, address, city, state, and zip code, and that interpreters listed must be certified pursuant to section 9795.1.6(a)(2)(A) and (B).
Applied to assess the validity of SCIF's MPN ancillary roster and the requirements for interpreter services.
Labor Code section 4616(b)(4)
Section 4616(b)(4) of the Labor Code provides that the Administrative Director's MPN determination may be appealed on the same grounds and within the same time limits applicable to a petition for reconsideration.
Applied to determine the appealability and timeliness of the petitions.
From the decision · page 3Section 4616(b)(4) provides that, "[a] determination of the administrative director may be reviewed only by an appeal of the determination of the administrative director filed as an original proceeding before the reconsideration unit of the workers' compensation appeals board on the same grounds and within the same time limits after issuance of the determination as would be applicable to a petition for reconsideration of a decision of a workers' compensation administrative law judge." (§ 4616(b)(4).) WCAB Rule 10560 provides that, "[w]here the Labor Code provides that the Workers' Compensation Appeals Board has jurisdiction over appeals from or enforcement of an order, any aggrieved party may appeal or seek to enforce an order issued by the Division of Workers' Compensation Administrative Director or the Director of Industrial Relations by filing
Labor Code section 4616(a)(4)(A)(i)
Section 4616(a)(4)(A)(i) requires that if the ancillary service is provided by an entity rather than an individual, the entity's name, address, and telephone number shall be listed on the MPN's internet website.
Applied to determine compliance of SCIF's MPN ancillary roster with publication requirements.
From the decision · page 8We note that the 2025 Determination Letter concludes that "DWC's independent review of the MPN Provider Directory search results and Roster of Participating Providers confirmed compliance with the Labor Code. The MPN listed interpreters with their individual or entity name, physical address, and telephone number." (ADJ8112676 (Chang) Exhibit E, MPN Determination Letter dated September 16, 2025, filed September 29, 2025 and October 8, 2025.) However, even if this was not true, and the MPN roster only provided, as lien claimant alleges, interpreting entities as opposed to individual interpreters, we note that section 4616(a)(4)(A)(i) states that if "the ancillary service is provided by an entity rather than an individual, then that entity's name, address, and telephone number shall be listed." Hence, we see no violation of the statute.
Labor Code section 4603.6
Section 4603.6 and AD Rules 9792.5.4 et seq. provide procedures for challenging payment disputes and require an independent bill review determination before an appeal to the Appeals Board.
Applied to defer the payment entitlement issue to the trial level for adjudication.
From the decision · page 9and invited lien claimant to verify that it is a provider under these entities and if it is not, to become a provider under these entities. (ADJ8112676 (Chang) Exhibit F, Advisory Reminder Notice to Ancillary Providers letter dated October 1, 2015, filed September 29, 2025 and October 3, 2025.) We further note that section 4603.6 and AD Rules 9792.5.4 et seq. are applicable procedures in challenging payment disputes. It is not until there is a determination of the independent bill reviewer that lien claimant can then filed an appeal with Appeals Board. (§ 4603.6(f).)
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About this page
- A published decision of the California Workers' Compensation Appeals Board, taken apart by what it turned on. The Board publishes the decision itself; this page adds the extraction and quotes the passage behind every claim.
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