What the panel ordered
Petition for reconsideration granted in part; December 5, 2025 Findings and Orders affirmed except amended to defer issue of statutory increase and interest on partially paid invoices; matter remanded to WCJ for further proceedings.
Petition for reconsideration filed by lien claimant Supreme Copy Service seeking review of the December 5, 2025 Findings of Fact and Order regarding reimbursement of medical-legal copy service charges and statutory interest.
This docket was decided more than once. Shown here is the latest released decision; we also hold August 1, 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 WCJ did not award statutory increase and interest on partially paid invoices due to lack of evidence on compliance with dispute resolution protocol; the WCAB deferred the issue for further record development.
From the decision · page 9Because the record does not contain evidence responsive to the parties' respective burdens of proof under section 4622, we are persuaded that the issue of whether statutory increase and interest attaches to the outstanding amount of the partially paid invoices must be deferred, pending development of the record.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
No evidence in record that defendant timely issued Explanation of Review (EOR) disputing reasonableness and necessity of medical-legal expenses.
Favours neutral
Without evidence of timely EOR, statutory increase and interest cannot be denied or awarded; issue deferred for further proceedings.
From the decision · page 9Because the record does not contain evidence responsive to the parties' respective burdens of proof under section 4622, we are persuaded that the issue of whether statutory increase and interest attaches to the outstanding amount of the partially paid invoices must be deferred, pending development of the record.
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Labor Code
Labor Code section 4622(a)(1) and related dispute resolution provisions
The statute requires payment of medical-legal expenses with statutory increase and interest unless timely contested by employer with Explanation of Review (EOR).
From the decision · page 5Section 4622 provides the relevant dispute resolution protocol for medical-legal expenses,
What proof carried it
The evidence the panel weighed, by kind.
Neither party produced evidence responsive to their respective obligations under Labor Code section 4622 regarding medical-legal expense dispute resolution.
From the decision · page 7[I]n this case, it has been 12 years since the original invoices were first sent to Defendants. At trial Defendants contended that too much time had passed and they no longer have documents in their possession to show they proceeded with the Explanation of Review (EOR). Moreover, Supreme Copy did not provide any evidence that they objected to the amount paid by Defendants. No objection letters were introduced into evidence. Further, Supreme Copy did not provide any documents requesting a second bill review on the unpaid invoices. Since neither party produced evidence to substantiate their contentions, this WCJ did not grant penalties and interests on the unpaid portions of the partially paid bills.
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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.
- The injured worker is not named here, and the case caption is not printed. Physicians appear as the decision names them, because a medical opinion is an act in a public proceeding.
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