workcompcentral has been alerted that the Court of Appeal has dismissed the Petition for Writ of Review of the California WCAB's En Banc decision in Kunz vs. Patterson Floor Covering (SJO 0224503, 12/05/02), letting the case stand as controlling law on outpatient surgical fees and lien claim issues.The WCAB in the Kunz case set forth standards for determining the reasonable value of
outpatient surgical procedures in the absence of a fee schedule, and also held that a defendant's failure to specifically object to a medical treatment lien claim on the basis of reasonable medical necessity (or ...
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