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.
- 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 → - ADJ11186589 · 2026-06-18 · Los Angeles District Office§ 4620
Determinative passage · p.5In the present matter, the WCJ found that lien claimant failed to establish any basis for reimbursement for the lien claim filed in this matter. We disagree. Here, the issue of whether lien claimant was entitled to payment for medical-legal costs was not an issue raised at trial. In the Petition for Reconsideration, lien claimant raises the issue because the WCJ found that it was not entitled to any payment.
Applied to defer issue of payment for medical-legal expenses pending adjudication of contested claim elements.
Official decision · page 5 → - ADJ8710590 · 2026-05-26 · Riverside District Office§ 4620
Determinative passage · p.7A cost petitioner holds the burden of proof to establish all elements necessary to establish its entitlement to payment for a medical-legal expense. (See § 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-
Cost petitioner met burden to show contested claim existed and services were reasonable and necessary; defendant failed to timely object with compliant Explanation of Review; cost petitioner entitled to reimbursement, penalties, and interest.
Official decision · page 7 → - ADJ10684244 · 2026-04-01 · Santa Ana District Office§ 4620
Determinative passage · p.5reimbursement 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).) Thus, a lien claimant 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. (Lab. Code, § 4620, 4621, 4622(f); Colamonico, supra, 84 Cal.Comp.Cases 1059.)
The WCAB applied these standards to determine that a contested claim existed at the time medical-legal services were provided, supporting reimbursement.
Official decision · page 5 → - ADJ7404188 · 2026-03-02 · Long Beach Office 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 § 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).)
The WCAB applied this standard to find that the cost petitioner met its burden to show a contested claim existed at the time the medical-legal copy services were provided.
Official decision · page 6 → - ADJ10790437 · 2026-02-09 · Riverside District Office§ 4620
Determinative passage · p.7A lien claimant 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; Torres v. AJC Sandblasting (2012) 77 Cal.Comp.Cases 1113, 1115 [2012 Cal. Wrk. Comp. LEXIS 160] (Appeals Board en banc).) Thus, a lien claimant 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 they were incurred. (Lab. Code, § 4620, 4621, 4622(f); American Psycometric Consultants Inc. v. Workers' Comp. Appeals Bd. (Hurtado) (1995) 36 Cal.App.4th 1626 [60 Cal.Comp.Cases 559].) Pursuant to Colamonico v. Secure Transportation (2019) 84
Applied to determine whether lien claimant met burden for medical-legal expenses.
Official decision · page 7 → - ADJ9935791 · 2025-12-15 · Van Nuys District Office§ 4620
Determinative passage · p.4A lien claimant 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), Labor Code section 46222 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).) Thus, a lien claimant 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. (Lab. Code, § 4620, 4621, 4622(f); Colamonico, supra, 84 Cal.Comp.Cases 1059.)
Lien claimant must show contested claim existed when expenses were incurred and that expenses were reasonable and necessary.
Official decision · page 4 → - ADJ8236211 · 2025-10-24 · Riverside 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 § 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." (§ 4622(f).)
Applied to determine burden of proof for medical-legal expense reimbursement.
Official decision · page 6 →
All 56 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 56 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.