As the Legislature printed it
DIVISION 4. WORKERS' COMPENSATION AND INSURANCE [3200 - 6002] · PART 2. COMPUTATION OF COMPENSATION [4451 - 4856] · CHAPTER 2. Compensation Schedules [4550 - 4856] · ARTICLE 2.5. Medical-Legal Expenses [4620 - 4628]
(a) For purposes of this article, a medical-legal expense means any costs and expenses incurred by or on behalf of any party, the administrative director, or the board, which expenses may include X-rays, laboratory fees, other diagnostic tests, medical reports, medical records, medical testimony, and, as needed, interpreter’s fees by a certified interpreter pursuant to Article 8 (commencing with Section 11435.05) of Chapter 4.5 of Part 1 of Division 3 of Title 2 of, or Section 68566 of, the Government Code, for the purpose of proving or disproving a contested claim. (b) A contested claim exists when the employer knows or reasonably should know that the employee is claiming entitlement to any benefit arising out of a claimed industrial injury and one of the following conditions exists: (1) The employer rejects liability for a claimed benefit. (2) The employer fails to accept liability for benefits after the expiration of a reasonable period of time within which to decide if it will contest the claim. (3) The employer fails to respond to a demand for payment of benefits after the expiration of any time period fixed by statute for the payment of indemnity. (c) Costs of medical evaluations, diagnostic tests, and interpreters incidental to the production of a medical report do not constitute medical-legal expenses unless the medical report is capable of proving or disproving a disputed medical fact, the determination of which is essential to an adjudication of the employee’s claim for benefits. In determining whether a report meets the requirements of this subdivision, a judge shall give full consideration to the substance as well as the form of the report, as required by applicable statutes and regulations. (d) If the injured employee cannot effectively communicate with an examining physician because he or she cannot proficiently speak or understand the English language, the injured employee is entitled to the services of a qualified interpreter during the medical examination. Upon request of the injured employee, the employer or insurance carrier shall pay the costs of the interpreter services, as set forth in the fee schedule adopted by the administrative director pursuant to Section 5811. An employer shall not be required to pay for the services of an interpreter who is provisionally certified unless either the employer consents in advance to the selection of the individual who provides the interpreting service or the injured worker requires interpreting service in a language other than the languages designated pursuant to Section 11435.40 of the Government Code.
How panels applied this section
Newest released decisions whose legal-standard extraction named this section. Each quotes the passage and links to the official PDF. Unofficial guide — not legal advice.
- ADJ21274145 · 2026-10-02 · San Bernardino District Office§ 4620
Determinative passage · p.8II. Section 4060(b) allows a medical-legal evaluation by the treating physician. Section 4620(a) defines medical-legal expense as “any costs and expenses…for the purpose of proving or disproving a contested claim.” Section 4064(a) states in part that “[T]he employer shall be liable for the cost of each reasonable and necessary comprehensive medical-legal evaluation obtained by the employee pursuant to Sections 4060, 4061, and 4062.” The regulations provide that the “primary treating physician shall render opinions on all medical issues necessary to determine the employee’s eligibility for compensation....” (Cal. Code Regs., tit. 8, §9785(d).) AD Rule 9793(h) states: (h) “Medical-legal expense” means any costs or expenses incurred by or on behalf of any party or parties, the administrative director, or the appeals board for X-rays, laboratory fees, other diagnostic tests, medical reports, medical records, medical testimony, and as needed, interpreter's fees, for the purpose of proving or disproving a contested claim. The cost of medical evaluations, diagnostic tests, and interpreters is not a medical-legal expense unless it is incidental to the production of a comprehensive medical-legal evaluation report, follow-up medical-legal evaluation report, or a supplemental medical-legal evaluation report and all of the following conditions exist:
These statutes were applied to determine the lien claimant's entitlement to payment for the medical-legal report.
Official decision · page 8 → - ADJ11249966 · 2026-10-02 · Anaheim District Office§ 4620
Determinative passage · p.6A cost petitioner holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See Lab. Code, §§ 3205.5, 5705.5; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 (Appeals Board en banc).) As we explained in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), section 4622 provides the framework for reimbursement of medical-legal expenses. Subsection (f) of the statute, however, specifically states that “[t]his section is not applicable unless there has been compliance with Sections 4620 and 4621.” (Lab. Code, § 4622(f).) WCAB Rule 10786 states in relevant part that: *** (b) If a defendant has failed to file and serve a petition for determination of medical legal expenses and a Declaration of Readiness in compliance with subdivision (a), a medical-legal provider may file and serve a petition for reimbursement of medical-legal expenses and a Declaration of Readiness to Proceed. Upon filing of a petition for reimbursement of medical-legal expenses and a Declaration of Readiness to Proceed, the medical-legal provider shall be added to the official address record.
Framework for reimbursement of medical-legal expenses and penalties for late payment
Official decision · page 6 → - ADJ9182040 · 2026-08-24 · Pomona District Office§ 4620
Determinative passage · p.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).)
Copy service fees are medical-legal expenses under Labor Code section 4620(a).
Official decision · page 4 → - ADJ17404265 · 2026-08-10 · Marina del Rey District Office§ 4620
Determinative passage · p.6in our en banc decision in Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), section 4622 provides the framework for reimbursement of medical- legal expenses. Subsection (f) of the statute, however, specifically states that “[t]his section is not applicable unless there has been compliance with Sections 4620 and 4621.” (§ 4622(f).) Thus, a cost petitioner is required to establish that: 1) a contested claim existed at the time the expenses were incurred; 2) the expenses were incurred for the purpose of proving or disproving the contested claim; and 3) the expenses were reasonable and necessary at the time were incurred. (§§ 4620, 4621, 4622(f); Colamonico, supra, 84 Cal.Comp.Cases 1059.) Here, in her Opinion, the WCJ concluded that a contested claim existed at the time that cost petitioner subpoenaed the records from applicant’s employer and that the subpoena was reasonable and necessary.
Applied to determine entitlement to payment and penalties for medical-legal expenses.
Official decision · page 6 → - ADJ19682404 · 2026-08-03 · Riverside District Office§ 4620
Determinative passage · p.8Section 4060(b) allows a medical-legal evaluation by the treating physician. Section 4620(a) defines medical-legal expense as “any costs and expenses…for the purpose of proving or disproving a contested claim.” Section 4064(a) provides that the employer is liable for the cost of a comprehensive medical evaluation that is authorized by section 4060. The regulations provide that the “primary treating physician shall render opinions on all medical issues necessary to determine the employee's eligibility for compensation...” (Cal. Code Regs., tit. 8, § 9785(d).) AD Rule 9793(h) states: (h) “Medical-legal expense” means any costs or expenses incurred by or on behalf of any party or parties, the administrative director, or the appeals board for X-rays, laboratory fees, other diagnostic tests, medical reports, medical records, medical
The Appeals Board held that Dr. Haghighinia’s medical-legal report is a compensable medical-legal evaluation and that the lien claimant met the burden to show a contested claim and reasonableness of the expense.
Official decision · page 8 → - ADJ4457963 · 2026-07-20 · Oxnard District Office§ 4620
Determinative passage · p.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.
The Board applied section 4620 to establish that the report addressed a contested claim and was a medical-legal expense.
Official decision · page 5 → - ADJ16164777 · 2026-07-07 · Van Nuys District Office§ 4620
Determinative passage · p.5IV. We highlight the following legal principles that may be relevant to our review of this matter: Section 4060(b) allows a medical-legal evaluation by the treating physician. Section 4620(a) defines medical-legal expense as “any costs and expenses … for the purpose of proving or disproving a contested claim.” Section 4064(a) provides that the employer is liable for the cost of a comprehensive medical evaluation that is authorized by section 4060. The regulations provide that the “primary treating physician shall render opinions on all medical issues necessary to determine the employee's eligibility for compensation …” (Cal. Code Regs., tit. 8, § 9785(d).)
These provisions govern the entitlement and timing of medical-legal reports and reimbursement of related expenses.
Official decision · page 5 → - ADJ8866704 · 2026-06-29 · Los Angeles District Office§ 4620
Determinative passage · p.4II. Pursuant to Colamonico v. Secure Transportation (2019) 84 Cal.Comp.Cases 1059 (Appeals Board en banc), a lien claimant holds the initial burden of proof pursuant under sections 4620 and 4621: that a contested claim existed at the time the expenses were incurred, that the expenses were incurred for the purpose of proving or disproving a contested claim, and that its services were reasonably, actually, and necessarily incurred. We stated that: 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." (§ 4620(a).) Copy service fees are considered medical-legal expenses under section 4620(a). (Citations) 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. Subsection (b) sets forth the parameters for determining whether a contested claim existed. (§ 4620(b).) Essentially, there is a contested claim when: 1) the employer knows or reasonably should know of an employee's claim for workers' compensation benefits; and 2) the employer denies the
The Appeals Board applied this standard to find that the cost petitioner met its burden to prove a contested claim existed at the time the services were rendered.
Official decision · page 4 →
All 63 decisions naming § 4620 →
The rules written under this section
A statute says what is owed; Title 8 says by when, on what form, and what happens if the deadline passes. These name § 4620as what they implement.
- 8 CCR § 10451.1Determination of Medical-Legal Expense Disputes. [Repealed]repealed
Also on this
Unofficial guide — not legal advice. The statute is the state’s text. The quotes are litigated applications, not a prediction.
About California Labor Code § 4620
What is California Labor Code § 4620?
Labor Code § 4620 sits in ARTICLE 2.5. Medical-Legal Expenses [4620 - 4628]. The statute on this page begins: (a) For purposes of this article, a medical-legal expense means any costs and expenses incurred by or on behalf of any party, the. The official display is on LegInfo; this is a reprint.
Did WCAB panels apply Labor Code § 4620 in this corpus?
This corpus has 63 released decisions whose extracted legal standards named § 4620. Quotes and PDFs are on this page. That is not every case in California that ever cited the section.