Workers’ Compensation · Primary-source case analysis

Tapia: A Medical Lien Claimant Must Prove Its Charges Were Reasonable

By Aneeta Mishra and Timothy Chan

Published May 20, 2026

Maria Tapia v. Skill Master Staffing addressed the proof needed to establish a medical provider’s lien when the parties disputed whether the billed charges were reasonable.

The claimant carried the initial burden

A lien claimant seeking payment had to establish, by a preponderance of the evidence, both the services rendered and the reasonable value of those services.

A bill did not prove its own reasonableness

The amount printed on an invoice showed what the provider charged, but it did not by itself demonstrate what was reasonably payable.

Relevant evidence was not limited to one formula

The parties could use testimony, market evidence, fee comparisons, contracts, payment history, or other reliable proof bearing on reasonable value.

The record controlled the result

Because the lien claimant had not supplied substantial evidence establishing reasonableness, the Board did not permit the unsupported bill to satisfy the burden.

Key takeaways

• Identify every service, date, and amount claimed.
• Collect admissible evidence of market value and customary payment.
• Separate proof that treatment occurred from proof of reasonable value.
• Build the lien record before the settlement or lien conference.