The Silent PPO Dilemma: California’s Medical Providers Harmed by Stealth Contracts Thursday, May 1, 2008 11:00 a.m. Pacific Time By Reid L. Steinfeld,

The Silent PPO Dilemma: California’s Medical

Providers Harmed by Stealth Contracts

Thursday, May 1, 200811:00 a.m. Pacific Time

By Reid L. Steinfeld, Esq. & David Bryan Leonard, Esq.

Important Terminology

• Preferred Provider Organizations (PPO) give discounts for increased patient volume.

• PPO Contract- A contract entered into by the provider and a network. The provider receives a referral, steerage, and/or preference, in return the provider discounts its medical fees.

• Health Care Contract- policies are issued to ensure members are identified by membership ID cards.

Important Terminology Continued

• Silent PPO- A “Silent PPO” is created when the PPO gains additional revenue by selling its reduced provider rates to payors (i.e. Work Comp Insurers) who are not a part to the preferred rate agreement with provider panels and who do not provide incentives for their beneficiaries to see these providers.

TWO TYPES OF PPO CONTRACTS

A contract in which the network contracts with the provider, for the network to sell its health care services at the contract rates agreed upon in turn for additional patients.

A Health Care Insurance Company that enters into contract with provider to treat their members of the insurance company issuing policy to its members at the discounted contract rates.

THE PROBLEM

•A billion dollar industry has been created by selling the contract discounts of PPO’s, for patients that are not members of the network for a fee.

HOW IT WORKS

HOSPITAL/PROVIDER

Patient with workers’ compensation insurance seeks treatment at hospital/provider.Insurance is verified.

1

Hospital/Provider generally toobusy to cross check to see if discount valid.

INSURANCE COMPANIES

Hospital bills insurer fee scheduleor usual and customary charges services.

Insurance Company

Hospital gets a reducedpayment from insurer alongwith EOB that says patientwas entitled to the discountthrough silent PPO.

6

2

BILL REVIEW CO/BROKER (SILENT PPO)

Review Co./Broker sells that information to insurer

5

Insurer contact broker of PPO discounts. Referred to as non-directedor silent PPO.

3

Review Co/Broker identifies PPO that has an agreement withhospital and obtainsdiscounted fee Information from thePPO.

4

PPO

First Case to Give the Board Jurisdiction

• Nico Zuniga, Applicant v. Herb Steward, State Compensation Insurance Fund, Defendants,2002 Cal. Wrk. Comp. P.D. LEXIS 104, Opinion Filed June 13, 2002

“While SCIF may have been a third-party beneficiary to the Blue Cross/Cedars-Sinai agreement in a Civil Code or Commercial Code setting, they may not assert such a right in a Worker’s Compensation case where Labor Codesection 5304 applies. This Labor Code section requires an “express agreement,” whether oral or written, between the provider and the employer or carrier. This provides a higher standard than civil or commercial contract law.”

The case also held that State Compensation Insurance Fund was entitled to the PPO discount of the Blue Cross contract.

When the case came out providers ready and willing to litigate based on the above case were dissuaded by direct asserts by Blue Cross that they considered such litigation a breach of their Blue Cross contract. Therefore, a mass litigation did not appear only a few providers continue to fight the “Silent PPO” issues.

OTHER CASES THAT ADDRESS LABOR CODE 5304

(JURISDICTION)

Maria Molina, Applicant v. Best Western Park Place Inn, State Compensation Insurance Fund, Defendants, 2005 Cal. Wrk. Comp. P.D. LEXIS 19, Opinion Filed February 7, 2005.

Labor Code Section 5304 states:“The appeals board has jurisdiction over any controversy relating to or arising out of Sections 4600 to 4605 inclusive, unless an express agreement fixing the amounts to be paid for medical, surgical or hospital treatment as such treatment is described in those sections has been made between the persons or institutions rendering such treatment and the employer.”

There is no contention by SCIF that an agreement fixing fees exists between SCIF and BMC(Bellflower Medical Center). Thus, this Court finds that jurisdiction exists to resolve this fee dispute between SCIF and BMC.

OTHER CASES THAT ADDRESS LABOR CODE 5304 (JURISDICTION)

• Virginia Woodruff, Applicant v. Greenfield Trucking, State Compensation Insurance Fund, Defendants, 2007 Cal. Wrk. Comp. P.D. LEXIS 93, Opinion Filed September 4, 2007Labor Code Section 5304 provides:

“The appeals board has jurisdiction over any controversy relating to or arising out of Sections 4600 to 4605 inclusive, unless an express agreement fixing the amounts to be paid for medical, surgical, or hospital treatment as such treatment is described in those sections has been made between the persons or institutions rendering such treatment and the employer or insurer.”

In this case, there is no evidence of an express agreement between the rendering institution, Good Samaritan Hospital and the insurer State Compensation Insurance Fund (SCIF). The only express agreements in evidence are between Good Samaritan Hospital and Blue Cross, and a separate agreement between Blue Cross and SCIF Two years separates the two agreements. At best, SCIF is a third party beneficiary, in a contractual sense, to the Good Samaritan/Blue Cross agreement. Since there is no express agreement between the institution rendering treatment (Good Samaritan Hospital) and the insurer(SCIF), the appeals board has proper jurisdiction over the matter under Labor Code section 5304.

JURISDICTION UNDER LABOR CODE 5304

• This case differs from the previous in that it was a brokerage contract. The case stated that since there were three contracts that was sufficient to deny the WCAB of Jurisdiction.

Sarah Waters, Applicant v. Los Angeles Clippers Basketball Club, Inc. TIG Specialty

Insurance Solutions c/o Cambridge Integrated Services Group, Inc., Defendants,

2005 Cal. Wrk. Comp. P.D. LEXIS 15, Opinions Filed February 7, 2005 and April 26,

2005

“The background to this issue is that CCN is in the business of preparing contracts and referring patients to doctors or hospitals, and there are other various aspects of its business as well, and CCN entered into a contract with Good Samaritan Hospital, under the terms of which Good Samaritan Hospital would accept for payment of medical treatment according to a scheduled fee. Later on, CCN entered into a separate contract with TIG.”

REVIEW COMPANY CUTS OFF BROKERAGE

CONTRACT

Richard Balzano, Applicant v. City of Los Angeles, PSI, Defendant, 2005

Cal. Wrk. Comp. P.D. LEXIS 16, Opinion Filed April 13, 2005

“The parties stipulated at trial that Diversified is listed as a “payor” on CCN’s payor list. According [sic] the definition of “payor” (supra), Diversified can only be classified as such in the capacity of an “employer”. They are not an insurance carrier, health care service plan, non profit hospital service plan, nor a governmental unit or any other entity which has an obligation to provide medical benefits to a beneficiary. Diversified can be a “payor” only in so far as their own employees (i.e. beneficiaries) are concerned. Testimony at trial was that Diversified did not pay any of the City of Los Angeles’ bills. They merely provided bill review and discounts and told the City of Los Angeles what they recommended the City pay. The City of Los Angeles actually paid the bills for medical treatment in this case.”

MORE ON REVIEW COMPANIES

Susan Olsukka v. City of Sacramento 2005 cql.Wrk Comp. P.D. LEXIS 27 Filed August 11, 2005

“It must be kept in mind that it was defendant, not Cambridge, that retained or authorized the services of lien claimant in this case. The evidence indicates an after-the-fact reduction by Cambridge based on a contract, that was never offered into evidence. Without this contract, the WCJ was, and remains, unable to determine if lien claimant agreed to be bound by the PPO price any time an employer or carrier retained Cambridge to review a bill.”

NO PRIVITY NO CONTRACT

John Miranda, Jr., Applicant v. The Pacific LumberCompany, Defendant, 2004 Cal. Wrk. Comp. P.D. LEXIS

90, Opinion Filed October 12, 2004

“WCAB found that there was insufficient evidence to establish the existence of an express agreement between defendant and lien claimant/medical provider fixing amounts to be paid for medical services, so as to remove the lien issue from WCAB jurisdiction under Labor Code Section 5304, when defendant was neither a “claims payor,” “beneficiary,” nor “employer” under the terms of lien claimant’s PPO contract and there was no privity of contract between the parties.”

OBLIGATION TO PAY ACCORDING

TO THE FEE SCHEDULE

Maria Molina, Applicant v. Best Western Park Place

Inn, State Compensation Insurance Fund, Defendants, 2005 Cal. Wrk. Comp. P.D. LEXIS

19, Opinion Filed February 7, 2005

“…, the WCAB has jurisdiction to resolve the fee dispute herein as the treatment in question was rendered to relieve or cure the applicant from the effects of an industrial injury. Further, SCIF was not a party to the agreement between BMC and Blue Cross. Thus, it is the opinion of this Court that SCIF has no standing to force the matter into arbitration.”

• “Thus, it would appear that as a matter of public policy, that unless there is an absolutely clear and unambiguous agreement to the contrary, the OMFS amounts should apply. There is no clear and unambiguous agreement between the provider Good Samaritan and SCIF in this case. As such, all else being equal, the OMFS should prevail.”

• The undersigned WCJ agrees with the general proposition asserted by Good Samaritan in its Response to SCIF’s Petition for Reconsideration that there is no showing that SCIF has complied with the provision of Labor Code 4609 and that such a so called “Silent PPO” is statutorily prohibited. In this case, contrary to the provisions of Labor Code 4609, Blue Cross appears to have sold its PPO discount to SCIF in contravention of this labor code provision.

Virginia Woodruff, Applicant v. Greenfield Trucking, State Compensation Insurance Fund, Defendants, 2007 Cal. Wrk. Comp. P.D. LEXIS 93, Opinion Filed September 4, 2007

Virginia Woodruff, Applicant v. Greenfield Trucking, State

Compensation Insurance Fund, Defendants, 2007 Cal. Wrk. Comp. P.D. LEXIS 93, Opinion Filed September 4,

2007“The term “other payor” as argued by the lien claimant is meant to refer to Blue Cross (card carrying) members, and there is no evidence that SCIF, an insurance company in and of itself was a member of Blue Cross or that applicant was a member of Blue Cross. SCIF or Blue Cross could have easily cleared up this ambiguity in the terms of the contracts by obtaining a contemporaneous addendum to the Blue Cross SCIF Agreement signed on behalf of Good Samaritan agreeing to be bound by the deep PPO discount. The parties failed to do this, leaving the ambiguous language in place. Obviously, Good Samaritan does not consider itself an “other payor” or it would not be litigating the matter. If the basic definition for a contract is that of a meeting of the minds between the contracting parties then no such meeting of the minds is demonstrated in this case.”

Maria Molina, Applicant v. Best Western Park Place Inn, State Compensation

Insurance Fund, Defendants, 2005 Cal. Wrk. Comp. P.D. LEXIS 19, Opinion Filed

February 7, 2005“SCIF contends that paragraph 2.2 of the agreement between BMC and Blue Cross (Defendant’s Exhibit F) identifies SCIF as a party defendant to the agreement. No such language exists that specifically identifies SCIF as a party, nor did SCIF execute the agreement. SCIF contends that any dispute regarding payment of BMC’s billings must be resolved via binding arbitration as set forth in the agreement between BMC and Blue Cross. As stated above, the WCAB has jurisdiction to resolve the fee dispute herein as the treatment in question was rendered to relieve or cure the applicant from the effects of an industrial injury. Further, SCIF was not a party to the agreement between BMC and Blue Cross. Thus, it is the opinion of this Court that SCIF has no standing to force the matter into arbitration.”

LABOR CODE SECTION 4609 (Silent PPO)

Virginia Woodruff, Applicant v. Greenfield Trucking, State Compensation Insurance Fund, Defendants, 2007 Cal. Wrk. Comp. P.D. LEXIS 93, Opinion Filed September 4, 2007

“The undersigned WCJ agrees with the general proposition asserted by Good Samaritan in its Response to SCIF’s Petition for Reconsideration that there is no showing that SCIF has complied with the provision of Labor Code 4609 and that such a so called“Silent PPO” is statutorily prohibited. In this case, contrary to the provisions of Labor Code 4609, Blue Cross appears to have sold itsPPO Discount to SCIF in contravention of this labor code provision.”

LABOR CODE SECTION 4609 begins with the intent of the code: that being prohibiting the selling of contract discounts

“a) In order to prevent the improper selling, leasing, or transferring of a health care provider’s contract…”

SB 559, which is the bill that created Labor Code Section 4609in the Assembly Analysis as to the purpose of the bill, stated as follows:

Purpose of the Bill. The California Chiropractic Association and the California Health Care Association representing hospitals, are sponsors of this bill. The sponsors indicate the bill is designed to stop “silent PPOs” from inappropriately marketing and selling lists of provider “panels” that offer discounted rates. Preferred Provider Organizations (PPO’s) are a type of managed care organization under which providers accept reduced payments in exchange for increased patient flow. Under these arrangements, individuals insured by a PPO plan are encouraged to use that plan’s “preferred providers” because the insurer pays a much higher proportion of the cost of service when it is rendered by a preferred provider.

LABOR CODE SECTION 4609

The sponsors argue a “silent PPO” is created when the PPO gains additional revenue by selling its reduced provider rates to payors (e.g. insurers) who are not party to the preferred rate agreement with provider panels and who do not provide incentives for their beneficiaries to see these providers. These unauthorized discounts cost hospitals and physicians large amounts of money. In many instances, the bill’s sponsors assert that providers never intended to extend discounts to these additional payors and had no knowledge that their services had been sold. The sponsors argue this bill is necessary to reject such “silent PPO” efforts without the fear of contract termination.

LABOR CODE SECTION 4609

The State of California and the former Governor

of California has recognized that the improper

selling of PPO discounts has cost the providers

and the citizens of California millions of dollars

every year. The American Medical Association

case called the “Silent PPO” fraudulent. Most

states, including California, have created laws

specifically prohibiting this practice.

SILENT PPO- A “SILENT PPO” IS CREATED WHEN THE PPO GAINS ADDITIONAL REVENUE BY SELLING ITS REDUCED

PROVIDER RATES TO PAYORS (I.E. WORK COMP INSURERS)WHO ARE NOT PARTY TO THE PREFERRED RATE AGREEMENT

WITH PROVIDER PANELS AND WHO DO NOT PROVIDE INCENTIVES FOR THEIR BENEFICIARIES TO SEE THESE PROVIDERS

NO CONTRACT

JURISDICTION

FEESCHEDULE

Nico Zuniga, Applicant v. Herb Stewart, State Compensation Insurance Fund,

Defendants, 2002 Cal. Wrk. Comp. P.D.LEXIS 104, Opinion Filed June 13, 2002

“While SCIF may have been a third-party beneficiary to the Blue Cross/Cedars-Sinai Agreement in a Civil Code or Commercial Code setting, they may not assert such a

right in a Workers Compensation case where Labor Code Section 5304 applies.

This Labor Code section requires an “express agreement,” whether oral or written, Between the provider and the

employer or carrier. This provides a higher standard than civil or commercial

contract law.”

Nico Zuniga, Applicant v. Herb Stewart, State Compensation Insurance Fund,

Defendants, 2002 Cal. Wrk. Comp. P.D.LEXIS 104, Opinion Filed June 13, 2002

“While SCIF may have been a third-party beneficiary to the Blue Cross/Cedars-Sinai Agreement in a Civil Code or Commercial Code setting, they may not assert such a

right in a Workers Compensation case where Labor Code Section 5304 applies.

This Labor Code section requires an “express agreement,” whether oral or written, Between the provider and the

employer or carrier. This provides a higher standard than civil or commercial

contract law.”

JURISDICTION

JURISDICTION

NO CONTRACTJohn Miranda, Jr., Applicant v. The Pacific Lumber Company, Defendant, 2004 Cal. Wrk. Comp. P.D. LEXIS 90, Opinion Filed October 12, 2004“WCAB found that there was insufficient evidence to establish the existence of an express agreement between defendant and lien claimant/medical provider fixing amounts to be paid for medical services, so as to remove the lien issue from WCAB jurisdiction under Labor Code Section 5304, when defendant was neither a “claim payor,” “beneficiary,” nor “employer” under the terms of lien claimant’s PPO contract and there was no privity of contract between the parties.”

JURISDICTION

JURISDICTION LABOR CODESECTION 4609

SILENT PPOCONTRACTS

OBLIGATION TO PAY ACCORDING TO THE FEE

SCHEDULE

Maria Molina, Applicant v. Best Western Park Place Inn, State Compensation Insurance Fund,

Defendants, 2005 Cal. Wrk. Comp. P.D. LEXIS 19, Opinion

Filed February 7, 2005

“…, the WCAB has jurisdiction to resolve the fee dispute herein as the treatment in question was rendered to

relieve or cure the applicantfrom the effects of an industrial injury. Further, SCIF was not

a party to the agreement between BMC and Blue Cross. Thus, it is the opinion of this

Court that SCIF has no standing to force the matter

into arbitration.”

Maria Molina, Applicant v. Best Western Park Place Inn, State Compensation

Insurance Fund, Defendants, 2005 Cal.Wrk. Comp. P.D. LEXIS 19, Opinion Filed

February 7, 2005

The language of Labor Code Section 5304 is clear and unambiguous. The WCAB has jurisdiction to resolve all

issues arising out of Labor Code Sections 4600 to 4605 unless an express

agreement exists employer or carrier. No such agreement exists between lienclaimant and BMC. Although, it may be

argued that SCIF is a third-party beneficiary to the agreement between

BMC and Blue Cross of California, Labor Code Section 5304 requires an express

agreement between the medical provider and the employer/carrier to remove

jurisdiction from the WCAB with respectto payment of fees for medical treatment.

This case differs from the previous in that itwas a brokerage contract. The case stated that since there were three contracts that

was sufficient to deny the WCAB of Jurisdiction.

Sarah Waters, Applicant v. Los Angeles Clippers Basketball Club, Inc. TIG Specialty

Insurance Solutions c/o Cambridge Integrated Services Group, Inc., Defendants, 2005 Cal. Wrk. Comp. P.D. LEXIS 15, Opinions Filed

February 7, 2005 and April 26,2005

“The background to this issue is that CCN is in the business of preparing contracts and

referring patients to doctors or hospitals, and there are other various aspects of its businessas well, and CCN entered into a contract with Good Samaritan Hospital, under the terms of which Good Samaritan Hospital would accept for payment of medical treatment according to a scheduled fee. Later on, CCN entered into a

separate contract with TIG.”

Virginia Woodruff, Applicant v. Greenfield Trucking, State Compensation Insurance Fund, Defendants, 2007 Cal. Wrk. Comp. P.D. LEXIS 93, Opinion

Filed September 4, 2007

Labor Code Section 5304 provides: In this case, there is no evidence of an express agreement between the

rendering institution, Good Samaritan Hospital and the insurer State Compensation Insurance Fund (SCIF). The only express agreements in evidence are between Good Samaritan Hospital and Blue Cross, and a

separate agreement between Blue Cross and SCIF. Two years separates the two agreements. At best, SCIF is a third party beneficiary, in a

contractual sense, to the Good Samaritan/Blue Cross agreement. Since there is no express agreement between the institution rendering treatment (Good Samaritan Hospital) and the insurer (SCIF), the appeals board has

proper jurisdiction over the matter under Labor Code section 5304.

LABOR CODE SECTION 4609 (Silent PPO)

Virginia Woodruff, Applicant v. Greenfield Trucking, State Compensation Insurance Fund, Defendants, 2007 Cal. Wrk. Comp.

P.D. LEXIS 93, Opinion Filed September 4, 2007

“The undersigned WCJ agrees with the general proposition asserted by Good

Samaritan in its Response to SCIF’s Petition for Reconsideration that there is no showing that SCIF has complied with the provision of Labor Code 4609 and that such a so called“Silent PPO” is statutorily prohibited. In this

case, contrary to the provisions of Labor Code 4609, Blue Cross appears to have sold its

PPO Discount to SCIF in contravention of this labor code provision.”

LABOR CODE SECTION 4609 begins with the intent of the code: that being prohibiting the selling of contract

discounts:“a) In order to prevent the improper selling,

leasing, or transferring of a health care provider’s contract…”

SB 559, which is the bill that created Labor Code Section 4609 in the Assembly Analysis as to the purpose of the bill, stated as follows:

REVIEWCOMPANIES

REVIEWCOMPANIES

REVIEW COMPANY CUTS OFF BROKERAGE CONTRACT

Richard Balzano, Applicant v. City of Los Angeles, PSI, Defendant, 2005 Cal. Wrk. Comp. P.D. LEXIS 16, Opinion Filed April

13, 2005

“The parties stipulated at trial that Diversified is listed as a “payor” on CCN’s payor list. According [sic] the

definition of “payor” (supra), Diversified can only be classified as such in the

capacity of an “employer”. They are not an insurance carrier, health care service plan, non profit hospital service

plan,nor a governmental unit or any other entity which has an obligation to provide

medical benefits to a beneficiary. Diversified can be a “payor” only in so

far as their own employees (i.e. beneficiaries) are concerned.

Testimony at trial was that Diversified did not pay any of the City of Los Angeles’ bills. They merely provided bill review and discounts and told the City of Los Angeles what they recommended the City pay. The City of Los Angeles actually paid the bills

for medical treatment in this case.”

MORE ON REVIEW COMPANIES

Susan Olsukka v. City of Sacramento 2005 cql. Wrk Comp. P.D. LEXIS 27 Filed

August 11,2005

“It must be kept in mind that it was defendant, not

Cambridge, that retained or authorized the services of lien

claimant in this case. The evidence indicates an

after-the-fact reduction by Cambridge based on a

contract, that was never offered into evidence. Without this contract, the WCJ was,

and remains, unable to determine if lien claimant

agreed to be bound by the PPO price any time an

employer or carrier retained Cambridge to review a bill.”

Purpose of the Bill. The California Chiropractic Association and the California Health Care

Association representing hospitals, are sponsors of this bill. The sponsors indicate the bill is

designed to stop “silent PPOs” from appropriately marketing and selling lists of provider “panels”

that offer discounted rates.Preferred Provider Organizations (PPO’s) are a type of managed care organization under which providers accept reduced payments

in exchange for increased patient flow. Under these arrangements, individuals insured by a PPO plan are encouraged to use that plan’s

“preferred providers” because the insurer pays a much higher proportion of the cost of

service when it is rendered by a preferred provider.

The sponsors argue a “silent PPO” is created when the PPO gains additional revenue by selling its reduced provider rates to payors

(e.g. insurers) who are not party to the preferred rate agreement with provider panels

and who do not provide incentives for their beneficiaries to see these providers. These unauthorized discounts cost hospitals and

physicians large amounts of money. In many instances, the bill’s sponsors assert that

providers never intended to extend discounts to these additional payors and had no

knowledge that their services had been sold. The sponsors argue this bill is necessary to reject such “silent PPO” efforts without

the fear of contract termination.

LABOR CODE SECTION4609 (SILENT PPO CONTRACTS)

The State of California and the former Governor of California has recognized that the improper selling of PPO discounts has cost the providers and the citizens of California millions of dollars every year. The American Medical Association case called the “Silent PPO” fraudulent. Most states, including California, have created laws specifically prohibiting this practice.

CONCLUSIONThis presentation is an attempt to show the participants a guide to

understanding the PPO dilemma in California. With the use of flow charts and cases, the hope is that sufficient information has been presented to support the proposition that “Silent PPO’s” are harming the providers and ultimately will harm society if the providers are unable or unwilling to treat Workers Compensation patients. Because of deep and severe discounts, the providers will be unable to afford to handlesaid patients.

The presenters suggest that the providers look closely at all of their contracts and when negotiating, make certain that their contracts are not susceptible to the “Silent PPO” practice, as well as, contacting their legislatures, as other states have done, including but not limited toTexas, Louisiana, and Ohio. Laws have been passed in these statesdealing specifically with the “Silent PPO” dilemma.

The quickest and easiest solution to this problem would be that the patients provide a “membership card” at the time of treatment so that there will not be any surprises when the provider’s bill is paid.

REFERENCES

• Nico Zuniga, Applicant v. Herb Stewart, StateCompensation Insurance Fund, Defendants, 2002 Cal.Wrk. Comp. P.D. LEXIS 104, Opinion Filed June 13, 2002• Maria Molina, Applicant v. Best Western Park Place Inn, State Compensation Insurance Fund, Defendants, 2005 Cal. Wrk. Comp. P.D. LEXIS 19, Opinion Filed February 7, 2005• Virginia Woodruff, Applicant v. Greenfield Trucking, State Compensation Insurance Fund, Defendants, 2007 Cal. Wrk. Comp. P.D. LEXIS 93, Opinion Filed September 4, 2007

REFERENCES

• Sarah Waters, Applicant v. Los Angeles Clipper Basketball Club, Inc., TIG Specialty Insurance Solutions c/o CambridgeIntegrated Services Group, Inc., Defendants, 2005 Cal. Wrk. Comp.P.D. LEXIS 15, Opinions Filed February 7, 2005 and April 26, 2005• Richard Balzano, Applicant v. City of Los Angeles, PSI, Defendant, 2005 Cal. Wrk. Comp. P.D. LEXIS 16, Opinion Filed April 13, 2005• Susan Olsukka v. City of Sacramento 2005 cql. Wrk. Comp. P.D. Lexis 27 Filed August 11, 2005• John Miranda Jr., Applicant v. The Pacific Lumber Company, Defendant, 2004 Cal. Wrk. Comp. P.D. LEXIS 90, Opinion Filed October 12, 2004

REFERENCES

• SB 559

• Labor Code Section 4609

• Labor Code Section 5304