Meadowbrook Ins. Co. v. Workers' Comp. Appeals Bd.Annotate this Case
In separate incidents, claimants Miguel Velazquez and Servando Velazquez suffered injuries within the scope of their employment, and each required Spanish language interpreting services in connection with their medical care. Meadowbrook Insurance Company was the workers’ compensation carrier for the claimants’ employers and accepted both claims and administered benefits. DFS Interpreting (“DFS”), which provided interpreter services to each claimant, timely submitted invoices to Meadowbrook for the services provided. Meadowbrook refused to pay the invoices DFS submitted. DFS objected to the insurance company’s explanations of review, but did not request a second review pursuant to Labor Code section 4603.2 (e) or California Code of Regulations, title 8, section 9792.5.5. Meadowbrook petitioned for writ of review of the Workers’ Compensation Appeal Board’s (WCAB) decision on reconsideration that liens held by DFS Interpreting (DFS) against Meadowbrook regarding unpaid invoices for interpreter services DFS provided to Meadowbrook’s insureds were not foreclosed by DFS’s failure to follow procedural rules. The Court of Appeal issued the writ, and held that DFS’s failure to comply with required procedures resulted in DFS’s bills being deemed satisfied. This result meant Meadowbrook was not liable for further payment. The Court annulled the WCAB’s decision to the contrary and remanded for further proceedings.