Approving restitution in these cases would set a precedent which would have unfortunate consequences for the workers'
compensation system. It would introduce the possibility of continued transactional instability so negative it would impact the
number of medical providers willing any longer to participate in the system by evaluating workers with industrial injuries. No
one can operate a business on receipts only conditionally. possessed, and medical providers are no exception. Thus we have
determined the restitution orders were unfair and must be annulled."
(American Psychometric Consultants, Inc. v. Workers' Comp. Appeals Bd. (Hurtado) (1995) 36 Cal.App.4th 1626, 1646 (60
Cal. Comp. Case 559)