Case Law regarding California Labor Code §4600 and PBNs:  In Jose Brambila v. Vons (ADJ724329), a permissibly self-insured and self administered employer duly established a PBN in January 2006 with appropriate notices to DWC. More importantly, they successfully implemented the PBN by providing appropriate notices, including a pharmacy card, to claimant Jose Brambila, who had self procured pharmaceuticals outside of the PBN. Subsequent to the resolution of the Brambila’s case, the employer took the pharmaceutical lien claimant to trial. Following testimony by the employer’s Director of Medical and Disability Management regarding implementation of the PBN, the trial Judge disallowed the pharmaceutical lien. The lien claimant appealed, and the WCAB panel affirmed the trial Judge’s denial of the pharmaceutical lien.   Although the Applicant was treating inside the MPN at the time the pharmaceuticals were procured, treatment inside an MPN is not required in order to enforce a PBN provided the appropriate notices are sent.