What the panel ordered
Petition for reconsideration granted; May 27, 2026 Findings and Order rescinded; new Findings of Fact substituted; case remanded to WCJ for further proceedingsp. 6
Petition for reconsideration of the May 27, 2026 Findings and Order granted by the WCAB panel
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 WCAB found that WCAB Rule 10545 does not apply to Supreme Copy's medical-legal copy service charges and that Supreme Copy may pursue reimbursement via lien filing or dispute resolution under WCAB Rule 10786, thus granting reconsideration and rescinding the prior Findings and Order.
From the decision · page 6billing pursuant to section 4622(c). (Cal Code Regs., tit. 8, § 10786(a).) In the event that the defendant does not timely request a hearing, the medical-legal provider may thereafter do so. (Id., subd. (b).) WCAB Rule 10786 provides specific conditions under which a defendant’s objection to the billing may be waived, and under what circumstances a provider’s bill will be deemed fully satisfied. (Id., subd. (e), (f), (g), & (h).) Rule 10786 does not require the filing of a lien as a precondition to seeking reimbursement of medical-legal expenses. Accordingly, we will grant reconsideration, rescind the F&O, and substitute new Findings of Fact that WCAB Rule 10545 is not applicable to the current dispute and that Supreme Copy may pursue reimbursement of its claimed charges using the procedures described in WCAB Rule 10786. We will then return this matter to the WCJ for further proceedings consistent with this opinion. We express no opinion as to the merits of Supreme Copy’s claim for reimbursement. For the foregoing reasons, IT IS ORDERED that reconsideration of the decision of May 27, 2026 is GRANTED.
The facts that decided it
What the panel treated as outcome-determinative, and which side it favoured.
WCAB Rule 10545 applies only to petitions seeking reimbursement for expenses not allowable as liens under Labor Code section 4903.
Favours Applicant prevailed
Because Supreme Copy's charges are medical-legal expenses allowable as liens under section 4903, Rule 10545 does not apply to their claim.
From the decision · page 5Code, § 4903(b) [“[T]he liens that may be allowed hereunder are as follows … (b) The reasonable expense incurred by or on behalf of the injured employee … and to the extent the employee is entitled to reimbursement under Section 4621, medical-legal expenses as provided by Article 2.5 (commencing with Section 4620) of Chapter 2 of Part 2, except those disputes subject to independent medical review or independent bill review”].) Here, the WCJ has applied an analysis of WCAB Rule 10545 to Supreme Copy’s charges. However, by its own terms, WCAB Rule 10545 applies to a petition seeking reimbursement of an expense or payment for service that is not allowable as a lien against compensation under section 4903.
Supreme Copy may pursue reimbursement of its claimed charges using the procedures described in WCAB Rule 10786.
Favours Applicant prevailed
This provides Supreme Copy with a clear path to resolution of its medical-legal expense dispute without the need to file a lien first.
From the decision · page 6billing pursuant to section 4622(c). (Cal Code Regs., tit. 8, § 10786(a).) In the event that the defendant does not timely request a hearing, the medical-legal provider may thereafter do so. (Id., subd. (b).) WCAB Rule 10786 provides specific conditions under which a defendant’s objection to the billing may be waived, and under what circumstances a provider’s bill will be deemed fully satisfied. (Id., subd. (e), (f), (g), & (h).) Rule 10786 does not require the filing of a lien as a precondition to seeking reimbursement of medical-legal expenses. Accordingly, we will grant reconsideration, rescind the F&O, and substitute new Findings of Fact that WCAB Rule 10545 is not applicable to the current dispute and that Supreme Copy may pursue reimbursement of its claimed charges using the procedures described in WCAB Rule 10786. We will then return this matter to the WCJ for further proceedings consistent with this opinion. We express no opinion as to the merits of Supreme Copy’s claim for reimbursement. For the foregoing reasons, IT IS ORDERED that reconsideration of the decision of May 27, 2026 is GRANTED.
The rules the panel named
Authorities as the decision cited them, with how this panel applied each one.
Cal. Code Regs., tit. 8, § 10545
WCAB Rule 10545
Rule 10545 does not apply to medical-legal expenses that are allowable as liens under Labor Code section 4903.
From the decision · page 5Code, § 4903(b) [“[T]he liens that may be allowed hereunder are as follows … (b) The reasonable expense incurred by or on behalf of the injured employee … and to the extent the employee is entitled to reimbursement under Section 4621, medical-legal expenses as provided by Article 2.5 (commencing with Section 4620) of Chapter 2 of Part 2, except those disputes subject to independent medical review or independent bill review”].) Here, the WCJ has applied an analysis of WCAB Rule 10545 to Supreme Copy’s charges. However, by its own terms, WCAB Rule 10545 applies to a petition seeking reimbursement of an expense or payment for service that is not allowable as a lien against compensation under section 4903.
Lab. Code, § 4620
Definition of medical-legal expense
Copy service fees are medical-legal expenses under Labor Code section 4620(a).
From the decision · page 4Supreme Copy contends that its charges are medical-legal in nature, and that it may pursue reimbursement of those charges either by the filing of a lien or through the procedures described in WCAB Rule 10786. (Cal. Code Regs., tit. 8, § 10786.) We agree. 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).) Copy service fees are considered medical-legal expenses under section 4620(a). (Cornejo v. Younique Cafe, Inc. (2015) 81 Cal.Comp.Cases 48, 55 [2015 Cal. Wrk. Comp. LEXIS 160] (Appeals Board en banc); Martinez v. Terrazas (2013) 78 Cal. Comp. Cases 444, 449 [2013 Cal. Wrk. Comp. LEXIS 69] (Appeals Board en banc).)
Cal. Code Regs., tit. 8, § 10786
Medical-legal expense reimbursement procedures
Medical-legal providers may pursue reimbursement via lien filing or dispute resolution procedures under Rule 10786 without filing a lien as a precondition.
From the decision · page 5Because medical-legal expenses are specifically allowed as a lien under section 4903, Rule 10545 is inapplicable to the instant claim of medical-legal expense. In addition to filing a lien for medical-legal expense under section 4903, a medical-legal provider may also elect to utilize the dispute resolution procedures set forth in WCAB Rule 10786. (Cal Code Regs., tit. 8, § 10786.) The Rule is designed to assist the parties to a medical-legal dispute with a clear path to resolution, including specific responsibilities for each party at various stages of the resolution process. The Rule requires that a defendant file a Declaration of Readiness to proceed within 60 days of objecting to a denial of all or a portion of medical-legal provider’s
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