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Understanding Accumulation of Permanent Disability Under LC 4664(c)(1)

Posted by:  Sure S. Log
Topics: Apportionment Permanent Disability PD accumulation LC 4664(c)(1) prior award regions of the body LC 4664

Labor Code § 4664(c)(1) states, "The accumulation of all permanent disability awards issued with respect to any one region of the body in favor of one individual employee shall not exceed 100 percent over the employee’s lifetime unless the employee’s injury or illness is conclusively presumed to be total in character pursuant to Section 4662." The regions of the body for the purposes of the statute are:

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Special Report: WCAB Issues En Banc Decision Regarding Application of Kite

Posted by:  Sure S. Log
Topics: Permanent Disability combining disabilities synergistic effect combining impairments PD Combined Values Chart reduction formula Kite

In 2013, the WCAB held in Athens Administrators v. WCAB (Kite) that an injured worker's disabilities are not required to be combined using the Combined Values Chart (CVC). The WCAB explained that although the AMA guides favor the combined values method, "physicians may, under certain circumstances, employ a different method of determining impairment if they remain within the four corners of the AMA Guides."

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