WCAB

Pursuant to Labor Code section 4603.2, subdivision (b), interest accrues on unpaid bills for compensable treatment of an injured employee under the workers’ compensation scheme when the employer challenges liability and does not pay the bill. The parties, here, dispute when the interest begins to accrue. We conclude that interest begins to accrue 60 days after the employer receives the bill, regardless of when the employer’s liability is admitted or accepted.

Background

In 1991, Florencio Lopez injured his back while working for Sheldon Moore, Inc. State Compensation Insurance Fund (State Fund) provided the company’s workers’ compensation coverage. During Lopez’s treatment, it was discovered that there was a preexisting mass in Lopez’s back which was compressing his spine. Medical care providers submitted bills as lien claims to State Fund for numerous surgeries and other treatment. State Fund did not pay the bills, denying liability for the treatment.

Although Lopez settled the case with State Fund, the settlement did not resolve the lien claims. Boehm & Associates (Boehm), on behalf of Medical, University of California at Davis Medical Center, University of…