PENNSYLVANIA WORKERS’ COMPENSATION
CASE SUMMARIES
04/1/2025 – 4/30/2025
RES JUDICATA
SUBSEQUENT ADJUCICATION
Christal Walker v. City of Philadelphia (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: April 15, 2025
Issue:
Whether the WCJ failed to abide by the factual findings of the prior WCJs?
Background:
Claimant sustained a work-related injury on April 13, 2010. Until that date, Claimant was working for Employer as a full-time data services clerk, a sedentary position involving data entry, typing, and faxing. Employer issued a NTCP. Claimant filed a Review Petition on December 3, 2010, alleging that the injury was insufficiently described in the NTCP. While the Review Petition was awaiting adjudication, Employer filed a Termination Petition. In a 2012 decision, the WCJ denied the Termination Petition and granted the Review Petition. Employer filed a Termination Petition in 2020. The WCJ denied the Petition. In 2021, Employer filed another Termination Petition. Additionally, Claimant and Employer filed petitions to review a UR Determination which found treatment by Claimant’s treating physician was reasonable and necessary in part. The WCJ granted the 2021 Termination Petition. Regarding the UR report, the WCJ only found treatment to be reasonable and necessary on one day only. Claimant appealed to the Board, which affirmed the WCJ.
Holding:
A WCJ can properly make a finding that an employer has met the standard set forth in Lewis by accepting medical evidence of full recovery, which would demonstrate a change in the claimant’s condition. The 2021 WCJ did not fail to follow the decisions of the prior WCJs. The question before the 2021 WCJ was not whether Claimant was fully recovered as of 2010, which was the question before a prior WCJ; nor was the question before him whether Claimant was less than 50% impaired as was before a WCJ; nor was it whether Claimant was fully recovered as of 2019. The question before the 2021 WCJ was whether Claimant was fully recovered in 2021. The previous WCJs, decisions are not binding on the 2021 WCJ, who was tasked with adjudicating a different issue and was free to make his own credibility determinations.
Affirmed.
ESTOPPEL
PAYMENTS IN LIEU OF COMPENSATION
Terry Stewart v. City of Philadelphia (WCAB)
Commonwealth Court of Pennsylvania – Published Opinion
Decided: April 15, 2025
Issue:
Whether the Employer’s use of E-time constituted payments in lieu of benefits that amounted to an acknowledgement that Claimant’s COVID was work-related and an acceptance of liability for his condition?
Background:
The Court noted that Stewart was 1 of 15 police officers represented by the same counsel who have filed similar claims based on the lasting effects of COVID, which they assert they contracted while working for Employer in late 2020. He asserted that Employer accepted his claim as a matter of law when it paid him wages in lieu of workers’ compensation benefits and then violated the Act when it unilaterally terminated those payments. Stewart knew that the pay he was getting then was not the standard injured on duty (IOD) pay. He was paid his full salary and did not have to use sick or vacation time. Later, Employer issued Stewart a notice of compensation denial (NCD). The NCD acknowledged notice of Stewart’s alleged work-related exposure to COVID as of October 30, 2022, but denied that his condition was work-related. His benefits ended in early March 2022. Employer explained that E-time is a timekeeping tool that enables an employee to continue to receive their salary when they can’t or they’re not at work for whatever reason; a way to let the people get paid and not sustain an adverse impact due to their missed time. It was not an acknowledgement that they contracted COVID at work. The WCJ denied Stewart’s reinstatement and penalty petitions. The Board affirmed.
Holding:
Even if Employer’s failure to issue Bureau documents and E-time payments to Stewart had given rise to the presumption of compensability, and even if Stewart’s notice to Employer had been deemed sufficient to convey his belief that his COVID was work-related, the record contains sufficient evidence to support a conclusion that Employer rebutted the presumption. Employer’s E-time payments were not intended to serve as wages in lieu of benefits because they were made to all employees who contracted COVID regardless of causation. Employer paid E-time to all employees who caught COVID during the relevant period, regardless of whether work-relatedness was asserted; without that distinction, the payments cannot reasonably be deemed in lieu of compensation. The record supports the WCJ’s finding that Employer never admitted liability or work-relatedness as to Stewart’s condition and that its E-time payments were not intended to be wages in lieu of workers’ compensation benefits. The WCJ did not err in concluding that Stewart did not meet his burden of proof. The opinion also presents an excellent discussion regarding the proper perspective on the “humanitarian purposes” of the Act.
Affirmed.
JUDICIAL DISCRETION
REJECTION OF TESTIMONY
Lebanon Transit v. Philip Schaeffer (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: April 7, 2025
Issue:
Whether the Board erred by accepting the credibility determinations of the WCJ as to Claimant’s testimony where the testimony is directly contradicted by other credible evidence of record?
Background:
Claimant filed a Claim Petition asserting that when he was working for Employer, he sustained an aggravation of the degenerative joint disease (DJD) in his right knee. The WCJ found Claimant credible regarding his history of right knee DJD, and the aggravation of his right knee DJD during the work incident. The WCJ concluded Claimant sustained a lumbar sprain and strain, and aggravation of his right knee DJD, and that he was entitled to benefits. Employer appealed the WCJ’s Decision to the Board, and the Board affirmed.
Holding:
Employer argued that the testimony of the Claimant relevant to a consideration of the issue of causation, is directly contradicted by the records of the Claimant’s own primary care provider. Regarding credibility determinations, the WCJ is the ultimate fact finder in workers’ compensation cases and is entitled to weigh the evidence and assess credibility of witnesses. The WCJ is free to accept or reject the testimony of any witness, including medical witnesses, in whole or in part. The Court will not disturb a WCJ’s findings so long as there is substantial evidence in the record to support those findings. The WCJ acknowledged Claimant conceded to having right knee DJD before the May 2021 work incident but accepted his assertion that his right knee problems worsened afterwards. The WCJ credited Claimant’s expert’s explanation over Employer’s that the work incident aggravated Claimant’s right knee DJD, a determination which was within his exclusive province as fact finder, and which is supported by substantial evidence. Further, that Employer does not agree with the WCJ’s credibility determinations does not mean the WCJ’s Decision was not a reasoned one.
Affirmed.
MEDICAL FEE REVIEW
CODING PROCEDURES
PMA Mgt. Corp. v. Fort Washington Surgery (Bureau of WC Fee Review Hearing Off.)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: April 3, 2025
Issues:
(1) Whether the surgical procedure code billed should be paid at the Medicare reimbursement rate for the year in which the service was performed; and (2) Whether the equipment codes billed were bundled with the payments for the surgical procedures billed?
Background:
Claimant sustained injuries in the course of her employment with the Employer. Claimant sought medical care for her work injuries, i.e., a lumbar spinal cord stimulator implant (Surgical Procedure), on June 9, 2021, at Provider’s ambulatory surgical center (ASC). PMA sent Provider Explanation of Benefits (EOB), for various charges, reducing some and denying others. Provider filed Applications for Fee Review. The ensuing administrative determination was then reviewed de no novo by HO Keller. HO Keller also made the following findings: (1) CPT Code 63650 was properly billed, is not subject to the multiple surgical procedure discount, should not be billed with 59 and SG modifiers, and is payable in accordance with the CMS published ASC fee schedule for the respective year of the date of service at issue; (2) CPT Code 95972-SG is bundled into the payment of the surgical procedure codes that were billed; and (3) the L-Codes at issue were bundled with the payment for the surgical procedures. Provider and PMA appealed to the Court.
Holding:
The Act requires that providers bill for procedures consistent with Medicare coding decisions pertaining to bundling, notwithstanding that the WC Fee Schedule did not change after Medicare implemented new bundling rules to include payment of implantable devices with the reimbursement of the surgical code. Accordingly, although reimbursements for those devices are included in the increased Medicare procedure code reimbursement rates, the devices are not compensable under the Act since the Act requires compliance with Medicare bundling rules, and the Act has not increased reimbursement rates to reflect the bundling within the procedure codes. Notwithstanding Medicare’s adjustment to the reimbursement rates to reflect the new 2008 bundling rules, Pennsylvania’s rate freeze meant that reimbursement rates were updated annually only in accordance with the percentage change in the SAWW and, thus, in contrast to changes made for Medicare reimbursements to reflect the modified Medicare bundling rules, no adjustment was made to reimbursements under the Act in response to the modified bundling rules. The Act and the MCC Regulations are unambiguous. The court considered the experts’ testimonies, in conjunction with a review of legislative intent. Act 44 included in Section 306(f.1)(3) of the Act both subpart ii, which froze the Medicare reimbursement rate for medical benefits as of December 31, 1994, and subpart vii, which, without any similar date restriction, prohibits a provider from fragmenting or unbundling charges except as consistent with Medicare. These provisions are unambiguous. Therefore, the Court inferred that the General Assembly intended for providers to adhere to Medicare bundling requirements after December 31, 1994. Further, Section 127.102 of the MCC Regulations does not authorize payment for the L-Codes. That section only provides for 80% reimbursement if a Medicare payment mechanism does not exist. Because Medicare has bundled reimbursement for the devices which are represented by L-Codes, a Medicare payment mechanism does exist. To permit providers to receive WC fee reimbursement for devices that Medicare has bundled would directly undermine Section 306(f.1)(3)(vii) of the Act, and Sections 127.102 and 127.204 of the MCC Regulations. Therefore, the Court affirmed the HO Order with respect to payment of the L-Codes. The Court reversed the HO Order to the extent that it directed that the surgical procedure code billed be paid at the Medicare reimbursement rate for the year in which the service was performed, rather than at the WC Fee Schedule amount for 2021; and affirmed the HO Order in all other respects.
Reversed in part.
EMPLOYMENT RELATIONSHIP – INDEPENDENT CONTRACTOR
BORROWED SERVANT
D&R Construction v. Hector Suarez, et al (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: April 28, 2025
Issues:
(1) Whether the Board erred in reversing the WCJ’s determination that Claimant was an independent contractor; (2) Whether the WCJ erred in concluding that Claimant was an employee of D&R, rather than T&L, at the time of his injury; (3) Whether the WCJ erred in rejecting D&R’s argument that Claimant was a borrowed employee; and (5) Whether the Claimant was not in the course and scope of his employment at the time of his injury because he violated a positive work order?
Background:
While working at a hotel construction site, Claimant fell approximately three floors from scaffolding and suffered serious injuries, including a fractured pelvis and ankle. Claimant filed a claim petition alleging that he sustained an injury in the course and scope of his employment with D&R. D&R filed an answer denying all material allegations and specifically averring that Claimant was not an employee of D&R but rather an independent contractor. D&R subsequently filed a joinder petition against T&L, alleging that T&L was the general contractor for the job on which Claimant was injured and, therefore, T&L was responsible for the payment of workers’ compensation benefits. Following remand, the WCJ issued a decision finding that Claimant was an employee of D&R because that entity had the right to control Claimant’s work and the manner in which it was done. The WCJ also rejected D&R’s argument that Claimant was a borrowed employee at the time of the incident. Thus, the WCJ granted Claimant’s claim petition against D&R. The Board affirmed.
Holding:
The existence of an employment relationship is a question of law to be determined based on the unique facts presented in each case. The Board properly focused on the control of the work and manner in which it is performed. Mr. Alcantara (of D&L) told Claimant what specific job to do each day; Claimant was responsible for cleaning up tools at the end of the day; Mr. Alcantara provided lodging and transportation to and from the work site; Mr. Alcantara admitted that Claimant had to adhere to his work schedule, including when he could take breaks; and that Claimant was paid at an hourly rate. Notably, Mr. Alcantara admitted to having the ability to control Claimant’s work and the manner in which it was performed. These facts, as a whole, point to the exercise of control by D&R, through Mr. Alcantara, and that Claimant was therefore an employee of D&R at the time of his injury. Claimant was not a borrowed employee. The test for determining whether an employee furnished by one person to another becomes the employee of the person to whom he is loaned is whether he passes under the latter’s right of control with regard not only to the work to be done but also to the manner of performing it. It is the right to control the manner of the work that is important, regardless of whether that control is actually exercised. Other factors that may be relevant include the right to hire and fire the claimant, the skill or expertise required to perform the work, and the payment of wages. The fact that Mr. Alcantara (of D&R) was not on the premises on the day Claimant fell does not automatically equate to control being passed to T&L simply because Mr. Wallace was present. In addition, Mr. Wallace was not an employee of T&L, but was the general contractor on the project, brought in to essentially manage the subcontractors. The credible evidence of record supports the finding that D&R retained control and, therefore, the WCJ did not err in rejecting D&R’s borrowed employee argument. The Board correctly determined that the WCJ erred in finding that Claimant was not furthering D&R’s affairs when he returned to the roof and that he violated a positive work order when he failed to wear his safety harness. Importantly, at the time he fell, Claimant was on the scaffolding attempting to retrieve tools from the roof, or at the very least ensure there were no tools left on the roof overnight. The record establishes that this was part of Claimant’s daily job duties. The incident also took place on the worksite shortly after Claimant’s workday had ended. In sum, it simply cannot be said that at the time of his injury, Claimant was engaged in an activity so disconnected with his regular duties as to be considered nothing more than a stranger or trespasser.
Affirmed.
REVIEW PETITION
NCP ISSUED BY MISTAKE
City of Philadelphia, et al. v. John Bell (WCAB)
Commonwealth Court of Pennsylvania – Published Opinion
Decided: April 2, 2025
Issue:
Whether, where the WCJ found the Medical-Only NCP was issued by mistake, did the WCJ commit legal error by not setting aside the Medical-Only NCP?
Background:
In June 2022, Claimant notified Employer he was diagnosed with colon cancer, specifically intra-mucosal adenocarcinoma, after serving as a City firefighter for 17 years. On September 26, 2022, Employer issued a Medical-Only NCP indicating Claimant sustained a work-related injury in the nature of colon cancer. On October 6, 2022, Employer filed a Review Petition alleging it mistakenly issued the Medical-Only NCP when it intended to issue a Notice of Compensation Denial.
Holding:
A WCJ may set aside a notice of compensation payable that is incorrect. However, the Act did not require her to set aside the incorrectly issued Medical-Only NCP. The WCJ’s Decision was supported by substantial evidence of record, and the WCJ did not capriciously disregard material competent evidence. The WCJ accepted Employer’s evidence and found Adjuster issued the Medical-Only NCP by mistake as she asserted. Nevertheless, because the WCJ had discretion to set aside the Medical-Only NCP, even where she accepted it was issued by mistake of the Adjuster, there was no legal error in the Board’s affirmance of the WCJ’s Decision. Further, the WCJ adequately explained the basis for her Decision such that appellate review was not impeded. Therefore, the WCJ’s Decision satisfies the reasoned decision requirement of Section 422(a) of the Act.
Affirmed.
SUBSTANTIAL EVIDENCE AND NOTICE
FIREFIGHTER CANCEL PRESUMPTION
Lake Ariel Volunteer Fire Co. v. Alex Rae (WCAB)
Commonwealth Court of Pennsylvania – Unpublished Memorandum Opinion
Decided: April 1, 2025
Issues:
(1) Whether Claimant timely notified Employer of a work injury; (2) Whether there was substantial evidence in the form of reports from the Pennsylvania Fire Information Reporting System (PennFIRS) or substantially similar reports to support a finding that Claimant was exposed to carcinogens; (3) Whether the WCJ capriciously disregarded competent evidence that Human Papillomavirus (HPV), with which Claimant was also diagnosed, causes oral cancer; and (4) Whether the WCJ failed to make essential findings of fact as to essential elements of the Claim Petition.
Background:
Claimant was diagnosed with various cancers after decades of being a firefighter, most recently as a volunteer for the Employer. Certain cancers are known to have a causal connection to firefighting, and so the legislature created a presumption that those cancers are caused by being a firefighter for purposes of the occupational disease provisions of the Workers’ Compensation Act. Claimant asserted he was diagnosed with “cancer of the head, neck, and throat/oral squamous cell carcinoma” following exposure to International Agency for Research on Cancer (IARC) Group 1 carcinogens while a volunteer firefighter for Employer. In March 2021, Claimant was diagnosed. Following his diagnosis, Claimant testified he informed Employer in writing and orally that he believed the cancer was caused from his firefighting service. Claimant’s full-time employment was at his restaurant and catering business, which served, among other things, barbecue. The business closed in 2017-18. Claimant helped his wife cook at times, he primarily worked in the front end and was not aware of any hazardous exposures. Claimant also served in Vietnam, where he was exposed to Agent Orange, and volunteered at the World Trade Center site. Claimant denied developing any cough after being at the World Trade Center site. The WCJ granted Claimant’s Claim Petition awarding benefits, and the Workers’ Compensation Appeal Board affirmed.
Holding:
The WCJ’s found that notice was provided to Employer on March 4, 2021. The only evidence in the record to support this date is the Claim Petition, averring Claimant verbally informed Employer on that date, which Employer denied in its Answer. However, Claimant testified to providing notice, albeit, he lacked any details, such as when and to whom notice was given. Nevertheless, the WCJ credited Claimant’s testimony, and the averments in the Claim Petition and Claimant’s credited testimony concerning notice were considered together, the WCJ committed no error. Instead of presenting PennFIRS reports, as provided by Section 301(f) of the Act, Claimant only presented lay testimony and data from the website, “iamresponding.com.” The summaries provided are the type of evidence authorized by this Court in Bristol Borough. The credited testimony, and documents, as summarized by the WCJ, specifically provides the findings of fact that Employer claims are needed to support the WCJ’s grant of the Claim Petition. The WCJ and Board did not err in concluding Claimant timely gave notice of his claim to Employer or in finding Claimant’s participation report sufficient to meet the Section 301(f) requirements. Additionally, the WCJ did not capriciously disregard evidence, and his decision was reasoned and contained the findings of fact necessary to support the grant of the Claim Petition.
Affirmed.
PENNSYLVANIA LEGISLATIVE REVIEW
House Bill 183
A few months ago, the Commonwealth of Pennsylvania, House L&I Committee, voted on what is now designated as HB 183. This Bill expands access to workers compensation disfigurement benefits by increasing the duration of eligibility from up to 275 weeks to a new level of up to 400 weeks, extending the benefit to the entire body, and not just to the head, face and neck, and allowing these benefits to be paid simultaneously with indemnity benefits. The bill was passed by the House on April 7, 2025, and has now been referred to the Senate Labor & Industry Committee. It is worthy of note that this bill was amended, just prior to passage, to apply to injuries for which “permanent disfigurement was reached” after the effective date of the provision, whereas it was previously intended to only apply to injuries sustained on or after the effective date.
NEW JERSEY WORKERS’ COMPENSATION
CASE SUMMARIES
4/1/2025-4/30/2025
BURDEN OF PROOF
Makins v. Palace Rehab & Care Center and Premier Cadbury, LLC
Superior Court of New Jersey – Unpublished Opinion
A-2263-23, A-2276-23; 2025 WL 1189475
Decided: 4/24/2025
Background:
Petitioner Dorothy Makins and Palace Rehab & Care Center (Palace), her former employer appealed a decision dismissing two workers’ compensation claim petitions filed against Premier Cadbury, LLC (Cadbury), another former employer. Petitioner was a licensed certified nursing assistant and worked for Palace from 2008 to 2016. The Petitioner worked for Cadbury from 2015 through 2018.
Petitioner filed a claim petition alleging she injured her back on June 5, 2013 while working for Palace. The claim was settled on August 22, 2017 via an Order Approving Settlement. In 2018, the Petitioner filed an application for Review or Modification alleging she was experiencing additional pain. Also in 2018, the Petitioner filed two additional claim petitions against Cadbury alleging injuries on February 11, 2018 and June 8, 2018.
The Judge issued an Order dismissing the Petitioner’s claims against Cadbury. The issue in dispute was whether the injuries were causally related to the alleged workplace accidents. The Judge found the Petitioner was not credible, noting that there were inconsistencies in her testimony and at times she did not respond to questions.
Petitioner argued on appeal the court confused medical causation and legal causation, improperly relied on her testimony to determine her credibility, and improperly relied on hearsay documents. Palace argued on appeal that the Judge improperly relied on documents.
Holding:
The court explained that to be awarded workers’ compensation benefits from Cadbury, the petitioner had to prove that the alleged incidents occurred and that she sustained her injuries from those accidents. The case was bifurcated and there was no objection to the bifurcation. Petitioner’s counsel chose not to call medical witnesses to challenge the documents and they reached an agreement regarding the admission of documents into evidence. There was no confusion of the Judge between medical causation and legal causation. There was no error in the Judge’s determination the petitioner’s testimony was not credible. It was based on her demeanor when she testified about facts, not just on her lack of memory. Further, Petitioner testified she signed the incident report and counsel from all parties consented to the documents being admitted into evidence. The Judge heard the Petitioner’s testimony and found her not credible, and the Petitioner chose not to bring a doctor to challenge the evidence. The Judge correctly concluded that Petitioner failed to meet her burden of proof.
Affirmed.
WORKERS’ COMPENSATION EXCLUSIVITY
Jameel v. Dember, HMH Hospital Corp.
Superior Court of New Jersey, Appellate Division – Unpublished Opinion
A-1225-23; 2025 WL 1217384
Decided: 4/28/2025
Background:
HMH Hospitals (HMH) employed both Jennifer Dember and decedent. Dember struck the decent by car in an HMH parking lot, causing fatal injury. Plaintiff, the administrator of the estate for decedent alleged HMH was negligent in the design and operation of the parking lot and also committed an intentional wrong because they created a substantial certainty that an employee would be seriously or fatally injured by the design of the parking lot. HMH denied allegations in the civil suit and asserted the workers’ compensation bar as an affirmative defense.
Dember struck decedent, resulting in death while decent was walking to work in HMH’s parking lot. Dember described a lack of crosswalks and stop signs. Dember was driving to a designated portion of the parking lot where employees were to park, at the time of the incident. Both sides presented experts.
The trial court found that there was no evidence HMH committed intentional acts that were substantially certain to result in injury or death and therefore granted summary judgment dismissal of the Workers’ Compensation Act (WCA) affirmative defense. The trial court also granted summary judgment dismissing plaintiff’s claim under the Act’s co-employee immunity provision because Dember and the decent were acting in the course and scope of their employment when the accident occurred.
On appeal, Plaintiff alleges the trial court erroneously granted summary judgment in part based on the intentional wrong/substantial certainty exception to the workers’ compensation bar and that the order granting summary judgment should be reversed.
Holding:
On appeal, Plaintiff alleges the trial court erroneously granted summary judgment in part based on the intentional wrong/substantial certainty exception to the workers’ compensation bar and that the order granting summary judgment should be reversed.
To determine whether an intentional wrong was committed, the employee must show: “(1) the employer must know that his actions are substantially certain to result in injury or death to the employee, and (2) the resulting injury and the circumstances of its infliction on the worker must be (a) more than a fact of life of industrial employment and (b) plainly beyond anything the Legislature intended the [WCA] to immunize.”
The court found that the plaintiff failed to establish the conduct prong and therefore, the appeal failed. HMH’s decision to instruct employees to use the parking lot which had lass safety protections for pedestrians did not constitute an intentional wrong. The decision to forego adding safety measures does not provide an objective basis that a reasonable juror could conclude and intentional wrong was committed. The court specifically noted the lack of evidence of deception, record of accidents, employee complaints, or injuries as a result of the lack of safety features supports that a reasonable juror could find that it was not substantially certain that a fatal accident would occur. Further, the court determined that the workers’ compensation immunity bar applies as the accident involved two employees, it was on HMH’s property in a designated employee parking area, and both employees were in the parking lot for the purpose to start their workdays.
Affirmed.
NEW JERSEY LEGISLATIVE UPDATE
Assembly Bill 4750
Expands certain employer reporting requirements to include entities that employ or contract with individuals for financial compensation, including ridesharing and delivery technology platforms.
Last Action: January 14, 2025 – Received in the Senate, Referred to Senate Labor Committee
Assembly Bill 4371/S1943
Requires workers’ compensation, PIP, and health insurance coverage for the medical use of cannabis under certain circumstances.
Last Action: May 16, 2024 – Introduced, Referred to Assembly Financial Institutions and Insurance Committee
Assembly Bill 4283
Provides personal liability for owner, executive officer, or executive director of employer for failure to pay for workers’ compensation coverage.
Last Action: May 6, 2024 – Introduced, Referred to Assembly Labor Committee
Assembly Bill 4559
Concerns certain workers’ compensation supplemental benefits and funding method.
Last Action: June 13, 2024 – Introduced, Referred to Assembly Labor Committee
Assembly Bill 2100
Provides workers’ compensation benefits for certain public safety workers who developed illness or injury as result of responding to September 11, 2001 terrorist attacks.
Last Action: September 19, 2024 – Reported out of Asm. Comm. With Amendments, and referred to Assembly Public Safety and Preparedness Committee
Senate Bill 3772
Concerns valuation of board and lodging with respect to workers’ compensation.
Last Action: December 5, 2024 – Referred to Senate Budget and Appropriations Committee
Senate Bill 794
Concerns workers’ compensation insurance requirements for certain corporations and partnerships.
Last Action: December 5, 2024 – Reported from Senate Committee as a Substitute, 2nd Reading
