EEOC Speaks Out on Workers Compensation ADA Obligations

Employers Must Begin Interactive Process for Return to Work Sooner Than Thought
Dated: December 4, 2014

[WorkCompRoundUp is authorized to provide this information on behalf of EEOC’s Aaron Konopasky, JD and Jennifer Christian, MD.]
EEOC’s Aaron Konopasky, JD and Jennifer Christian, MD Provide Guidance on When Employers Must Start Discussion Regarding Return to Work Accommodations

 

This may be surprising news for some readers: In workers’ compensation, MMI should not be viewed as the trigger for ADA-related protections and obligations.

 

Background: A common practice in workers’ compensation claims management may not be legal. Employers / claims organizations that postpone the reasonable accommodation process until an injured worker’s medical condition has reached MMI (maximum medical improvement) may be violating the ADA, now that the definition of “disability” has been broadened. Prior to MMI, if medical restrictions have been established by the treating physician, employers often decide whether to offer temporary transitional work without involvement of injured workers. If not, the workers remain out of work – and may end up losing their jobs. Jennifer Christian, MD, MPH who chairs ACOEM’s Work Fitness & Disability Section, asked Aaron Konopasky, JD, PhD, a senior attorney advisor to the EEOC about this. She was surprised to hear that the ADA does apply at any time – whenever a medical condition has the potential to significantly disrupt an employee’s work participation. This means that injured workers will need to be active participants in their employers’ stay-at-work and return-to-work decision-making process. Christian and Konopasky agreed to co-author a brief summary of the way these two programs interact during the post-injury period, which appears below. Please forward this on to anyone who needs to know.

 

In the Worker’s Compensation context, ADA-related issues can arise at any of several points along the injury management timeline. As a practical matter, employers should be pro-actively evaluating and managing Worker’s Compensation and ADA legal issues concurrently.

 

This is because an employer’s reasonable accommodation-related obligations begin as soon as the employer knows that an individual worker is having trouble at work because of a serious medical problem. By definition, if a doctor informs the employer that a worker has medical restrictions/limitations due to a work-related condition, whether or not the employee is actually working, the employer is now aware that a medical problem is having an impact on the employee’s ability to work. If the condition has the potential to significantly disrupt the employee’s work participation, the employer should immediately engage the worker in an interactive process to look for a reasonable accommodation under the ADA.

 

Although the employer can stop at this point to determine whether the individual is a “qualified individual with a disability,” it may not be worthwhile. Since employees with workers’ comp injuries are already employed at the time of injury, one can presume they meet the requirement of being “qualified” for the job. And, under the much broader standards established by the ADAAA, any conditions serious enough to require medical restrictions/limitations for more than a few days or weeks (and even some conditions that have not yet caused any work disruption) are likely to meet the definition of an ADA “disability.” An extended inquiry regarding the applicability of the ADA could result in unnecessary delay during a critical period.

 

Thus, whether or not the worker’s condition is stable and has reached maximum medical improvement (is at MMI) has no relevance, either (a) to the time when the employer’s obligation to engage in the interactive process begins or (b) to the time when a worker should be considered a qualified individual with a disability under the ADA. For more details about specific times when the ADA may apply, read below.

 

1. At the time a person is injured.
No matter whether the resulting condition is already stable or is still evolving, the ADA may require the employer to provide a reasonable accommodation that would enable the individual to perform his or her essential job functions, unless doing so would involve significant difficulty or expense. Examples might include specialized equipment, removal of non-essential job functions, and special scheduling. Individualized assessment is a key precept of the ADA, so a blanket policy is not appropriate. Employers might also choose to reduce job demands or productivity expectations on a short-term basis, although this would not be required by the ADA. It should be noted, though, that the ADA cannot be used to deny a benefit or privilege to which the employee is entitled on a separate basis. If, for example, the individual has other types of leave available at his or her discretion, whether paid (such as vacation leave) or unpaid (such as FMLA leave), the employer cannot deny that leave based on the fact that he or she could remain on the job with a reasonable accommodation.

 

2. While recovering out of work due to injury
The ADA may apply as soon as the worker’s condition becomes stable enough that on-the-job reasonable accommodations might allow the individual to perform the essential functions of the job (whether or not there has been a formal declaration of MMI). A blanket policy is not appropriate at this juncture, either. At this point, the employer should re-engage the interactive process to determine whether a reasonable accommodation would allow the individual to return to their usual job. As mentioned above, employers might also choose to reduce job demands or productivity expectations on a short-term basis, although this would not be required by the ADA.

 

3. When the individual has exhausted his or her leave and workers’ compensation benefits, and is still unable to return to the original position, even with an on-the-job reasonable accommodation.
At this point, whether or not the medical condition has reached MMI, the employer should consider other forms of reasonable accommodation, such as additional unpaid leave or, if the individual is not expected to regain the ability to do the essential functions of his or her current position, reassignment to a vacant position (if one is available). Again, a blanket policy is not appropriate.

 

In summary, legal obligations under Worker’s Compensation and ADA legal issues should not be assumed to be sequential, because they may run simultaneously. Duration is not the key issue; the main issue is the nature of the condition and its impact on the ability to function at work.

 

 

CLARIFICATION To MEMO dated December 4, 2014
Dated: December 11, 2014

The EEOC’s Aaron Konopasky and I were glad to see many thoughtful comments in response to our message about the ADA in workers’ compensation last week in the forums where it was posted. Our summary was primarily written to dispel two common myths:

  1. In workers’ compensation, the time to think about the ADA is at MMI. This is NOT true. MMI is late among several points in the post-injury timeline when the ADA needs to be considered.
  1. The ADA’s requirement for an interactive process doesn’t apply in decision-making about transitional work assignments. This is NOT true. Injured workers do need to be active participants in the workers’ comp stay-at-work and return-to-work process.

 

However, based on the comments we have received, we want to clarify that the ADA has several other significant implications for how employers should respond to existing employees who develop health problems. The ADA is about civil rights for people with disabilities, not financial benefits of one kind or another. The fundamental purpose of the ADA’s employment provisions is to help people with disabilities get and keep jobs, as long as they are qualified to do the work and can meet productivity standards. The cause of the disability is irrelevant. It does not matter what other types of policies or programs are also involved — whether workers’ compensation, FMLA, sick pay, or disability insurance programs. A disability can be newly acquired, transitory, fluctuating, progressive, or longstanding and stable. It can be the result of injuries, illnesses, congenital conditions, or the natural aging process. The only relevant question is whether the disability is now or is perceived as potentially having a significant impact on someone’s ability to perform their job, take home their regular paycheck, and stay employed.

 

Here are 5 more practical implications for management of ALL types of health-related employment situations:

 

  1. As the Federal agency that enforces the employment provisions of the ADA, EEOC’s biggest concern in situations involving disability leaves of any type will be that someone with a disability is being forced to take leave even though he or she could do the essential functions of the job with a reasonable accommodation. Everyone involved in the decision to keep someone out of work — doctors, third-party benefit administrators, managed care companies, workplace supervisors and employee program managers — should keep that fact firmly in mind, so that people with disabilities are not needlessly forced out of the workplace.

 

  1. Only the employer is accountable for complying with the employment provisions of the ADA. However, treating physicians and the employer’s vendors (benefits claims administrators, managed care companies) who fail to communicate with the employer during the stay-at-work and return-to-work process may be exposing the employer to increased risk/liability. When a vendor or a doctor (especially one who has been selected by the employer) fails to notify the employer that an employee described difficulty working or an adjustment that might allow them to work, the employer could be held liable for failing to provide that accommodation — even though the information was never properly passed along. Doctors and vendors also can help educate employees and small or unsophisticated employers to ensure that the law is followed.

 

  1. Some employees may express the desire to remain on leave, rather than return to work with a reasonable accommodation. Of course, employees with disabilities must be allowed to use accumulated sick or annual leave, just like any other employee. And they may have a legal right to insist on leave if, for example, they qualify for FMLA. But if an individual with a disability has no discretionary leave, and a reasonable accommodation would allow performance of job functions in a manner that is safe and consistent with his or her medical needs, then the employee may be required to return to work with the accommodation.

 

  1. Paying people money to sit home who are well enough to do something productive does not count as a reasonable accommodation under the ADA, especially when they were not part of the decision-making process that has put them out of work. The employee must be actively involved in arranging any temporary or long-lasting adjustments to their usual jobs in order for the employer to meet the interactive process obligation. With respect to specific cash payments made under workers’ compensation—

 

A.  Temporary Total Disability (TTD) Benefits – There is little difference between cash payments under workers’ comp TTD and disability benefit programs for personal health conditions except how the amounts are calculated. Employees are usually receiving them for one of four reasons:

 

  1. The doctor wrote “no work” because their patient’s medical condition is so severe or unstable that it is unsafe for them to do anything except try to get better;
  2. The doctor wrote “no work” because of a perception that the employer cannot or will not provide safe and suitably modified work on a temporary or long-term basis;
  3. The doctor released their patient to work with restrictions, but state or federal law, or a union contract means that the employee cannot work until fully able to do the essential functions of their job, so the employee is put out of work temporarily.
  4. The doctor released their patient to work with restrictions, but the employer said they cannot meet those restrictions (cannot find appropriate work to assign them within their current work capacity) so the employee is put out of work.

 

In all but # 1 above, the ADA may apply. However, the employee is often not consulted as these decisions are being made. As stated above, giving the employee money is not a reasonable accommodation, and the ADA requires that the employer interact with the employee in looking for a solution that will enable the employee to stay at work.

 

B. Other types of cash benefits: Temporary Partial Benefits, Permanent Partial Benefits and Permanent Total Benefits -These cash awards help compensate employees for economic loss as a result of their injuries. However, as stated above, giving people money is not a reasonable accommodation, and does not accomplish the public purpose of the ADA.

 

5. Employers sometimes limit the length of transitional work assignments (TWA) in order to avoid them turning into required permanent accommodations or becoming subject to union job bid rules. To avoid ADA liability, a “usual” 90-day limitation policy that provides for an individualized assessment of the individual’s situation and possible extension is more appropriate. If there is a specific reason why extending a particular employee’s TWA or granting extra (paid or unpaid) time off to heal more completely will allow them to keep their job that might be a reasonable accommodation. Some temporary adjustments are reasonable accommodations (including, for example, temporary use of adaptive equipment or temporary relocation of a workstation to the ground floor) and may need to be extended unless doing so would involve significant difficulty or expense. However, TWAs may have other aspects that can be discontinued without fear of ADA liability, including temporary reductions in productivity requirements and elimination of essential job functions. These measures go beyond what the ADA requires.

 

 

Please note that this material is an informal discussion and does not constitute an official opinion or interpretation of the EEOC.

 

 

Aaron Konopasky, J.D., Ph.D
Senior Attorney Advisor
ADA/GINA Policy Division
Equal Employment Opportunity Commission
Email: aaron.konopasky@eeoc.gov

 

Jennifer Christian, MD, MPH
President, Webility Corporation
Chair, Work Fitness & Disability Section
American College of Occupational & Environmental Medicine
Email: Jennifer.christian@webility.md

 

If you would like to hear directly from the EEOC, inquiries can be submitted by mail to:

EEOC Office of Legal Counsel
131M Street, NE
Washington, DC 20507

 

Download A Printable Copy of This Memo

Go to Jail, Do Not Pass Go (Go = Work Comp Insurance)

The Illinois Government News Network had an interesting news release recently about the pitfalls of not having workers’ compensation insurance.

 

 

Company Never Purchased Workers Compensation Insurance

 

Mr. Ahmed Ghosien, of Hometown, IL, d/b/a Ghosien European Auto Werks, felt he could skirt the Illinois statute requirement to provide workers’ compensation coverage for his auto mechanics and support staff.  The Illinois Workers’ Compensation Commission (IWCC) discovered Mr. Goshien had never purchased workers’ compensation insurance for the employees of his repair shop.

 

In March, 2010, the IWCC served Mr. Goshien with a Notice of Non-Compliance.  Mr. Goshien in April, 2010 obtained his first workers’ compensation insurance policy.  In a July, 2010 settlement agreement with the IWCC, Mr. Goshien agreed to pay a $25,000 fine at the rate of $5,000 per month for five months.  Mr. Goshien failed to make any of the five payments.

 

The workers’ compensation policy obtained by Mr. Goshien in April, 2010 was cancelled in December, 2011 for non-payment of the insurance premium.   The efforts of the IWCC to resolve the conflict with Mr. Goshien were not successful, as he failed to get his workers’ compensation insurance reinstated and refused to pay the IWCC fine. 

 

 

Owner Received Criminal Indictment & Fines

 

Mr. Goshien secured workers’ compensation insurance in February, 2013, but only after he learned of a criminal indictment against him.  The IWCC Compliance Unit, the Cook County Illinois Sheriff’s office and Cook County State’s Attorney’s Special Prosecutions Division working together, for over a year on this matter, had secured a felony indictment against Mr. Goshien in November, 2012 for the intentional violation of the Illinois workers’ compensation statute.

 

Prior to 2005, the failure to obtain workers’ compensation insurance was a misdemeanor in Illinois.  In 2005, the failure to be insured for workers’ compensation was changed from a misdemeanor to a Class 4 felony, which carries penalties of 1 to 3 years in the penitentiary and/or fines of up to $25,000.  It remained a Class 4 felony when Illinois passed the revised Workers’ Compensation Act of 2011.

 

 

 

Failure To Obtain Workers Comp is Class 4 Felony That Will Cost Jail Time

 

Following several continuances, Mr. Goshien on July 25, 2013 entered a guilty plea to the Class 4 felony charge.  He will return to court in October, 2013 for sentencing, pursuant to the pleas agreement and agreement to pay a fine of $25,000.

 

IWCC Chairman Michael P. Latz released a statement of “Employers who refuse to obtain workers’ compensation insurance put their employees at risk, gain an unfair advantage over law-abiding competitors and ultimately shift the cost of their business to the Illinois taxpayers.”

 

Mr. Goshien’s efforts to avoid purchasing workers’ compensation insurance will most likely end up with him going to jail.  While employers may resent the state mandating their purchase of workers’ compensation insurance, it is the law in every state (with specific exceptions), and there is no reason for an employer to go to jail over not having workers’ compensation insurance.

 

While you cannot avoid the requirements to have workers’ compensation insurance, you can reduce the cost of workers’ compensation.  For more information on how your company can lower the cost of workers’ compensation (without going to jail), please contact us. 

 

 

Author Michael B. Stack, CPA, Director of Operations, Amaxx Risk Solutions, Inc. is an expert in employer communication systems and part of the Amaxx team helping companies reduce their workers compensation costs by 20% to 50%. He is a writer, speaker, and website publisher.  www.reduceyourworkerscomp.com.  Contact: mstack@reduceyourworkerscomp.com.

 

©2013 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.


Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional about workers comp issues.

Work Place Safety Violation Imposed For Dropping Debris Three Floors

 

 
Not providing safe conditions for its employees has led to a fine for one Scottish firm.
 
According to information from the Health and Safety Executive (HSE), the County Durham construction firm was fined for dangerous practices on a building site in Aberdeen.
 
Following an anonymous complaint to the HSE, inspectors arrived for an unannounced visit to the former Grampian Hotel site in Carmelite Street in June of 2010.
 
Work was underway to convert the building into a 30 flat development and the principal contractor was MK Builders (North East) Ltd, which had overall responsibility for the site.
 
 
Workers Dropping Debris Through 3rd Floor Hole In Floor
 
Aberdeen Sheriff Court heard in late March that on arrival the inspectors opened a door at the rear of the building and discovered debris was being dropped via the internal structure from the third floor to the ground level. Timber was piled up beneath a hole in the ceiling and there was nothing on the door to warn of the potential dangers inside.
 
HSE established that one employee was accumulating debris on the third floor and depositing it through the hole in the floor. Similar holes had been left in the floor at each level in order to permit the debris to fall, and all presented a fall risk because of unprotected open edges leading to falls of between 10 and 30 feet.
 
The court was informed the worker on the third floor was carrying a fall arrest harness, which is typically used as the last line of defense to reduce the risks of falling, but is not considered sufficient protection on its own.
 
 
Company Pleaded Guilty and Fined $6,000
 
HSE also found that the ground floor area, and in particular a door labeled as a fire exit, were blocked by materials that had been dropped from height. The door was also used to access the portable toilet outside and workers would apparently yell up when walking through this area.
 
A pair of Prohibition Notices were served to stop any further work being carried out near the open flooring until suitable fall prevention measures were in place, and to stop debris being thrown through the holes in the floor to prevent others being struck by falling objects.
 
MK Builders (North East) Limited, of Gainford House, Picktree Lane, Chester-le-Street, found itself with a total fine of more than $6,000 after pleading guilty to a pair of separate breaches of the Work at Height Regulations 2005.
 
 
Author Michael B. Stack, CPA, Director of Operations, Amaxx Risk Solutions, Inc. is an expert in employer communication systems and part of the Amaxx team helping companies reduce their workers compensation costs by 20% to 50%. He is a writer, speaker, and website publisher.  www.reduceyourworkerscomp.com.  Contact: mstack@reduceyourworkerscomp.com.
 
©2013 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law.

Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker, attorney, or qualified professional about workers comp issues.

New Zealand Improves Return to Work Ratio for Injured Workers

New Zealand’s Accident Compensation Corporation continued to improve its performance rehabilitating injured New Zealanders this past financial year according to a recent report.
 
 
The report says four key rehabilitation indicators improved during the year. They are: people no longer dependent on ACC after 70 days: – 71 percent, up from 67 percent  two years ago; people no longer dependent on ACC after 273 days: 93 percent, up from 91 percent two years ago; number of people on ACC long term: about 12,000, down from 14,500 two years ago; proportion of people going on to require time off work after an injury: 3.25 percent, down from 4.1 percent two years ago. (WCxKit)
 
 
Getting people back to their normal lives, as far as possible and as soon as possible is ACC’s core role. So these results are very pleasing,” said ACC Chairman John Judge. “Additionally, this improved performance has led to a further reduction in ACC’s net deficit, making the scheme more sustainable into the future.”
 
 
Preliminary financial results for the 2010-11 year show a forecast net surplus of about $2.5 billion. That means the corporation’s net deficit will fall from last year’s $10.3 billion to about $7.8 billion.
 
 
The $2.5 billion surplus is calculated by figuring improved performance of the insurance business, improved investment performance, economic, and miscellaneous  factors. Overall, ACC's scheme solvency has improved to 72% from just 46% two years ago. These results are due to a range of factors, most notably improved rehabilitation of injured clients and improved investment returns. It has also reportedly been important that ACC has stuck more closely to its legislation than was perhaps the case in the past.
 
 
ACC received over 1.6 million new claims this year. By helping these people get back to work or gain independence faster we’ve not only improved their lives but also lowered our own claim costs and stopped the growth in our future liabilities that was so severe for so many years,” Judge said. (WCxKit)
 
 
This is a great result, due in no small part of the efforts of ACC staff, but there is still a long way to go. The remaining deficit of $7 billion is still a major issue and now is not the time to rest on our laurels. These positive trends could easily reverse,” Judge added.

 Author Robert Elliott, executive vice president, Amaxx Risks Solutions, Inc. has worked successfully for 20 years with many industries to reduce Workers Compensation costs, including airlines, healthcare, printing/publishing, pharmaceuticals, retail, hospitality and manufacturing. See www.LowerWC.com for more information. Contact:  Info@ReduceYourWorkersComp.com.
 
Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker or agent about workers comp issues.
 
©2011 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law. If you would like permission to reprint this material, contact Info@ReduceYourWorkersComp.com.

Workplace Absence Costing British Economy Big Bucks

Great Britain's economy lost 190 million working days to absence in 2010, with each employee taking an average of 6.5 days off sick, according to the latest CBI/Pfizer Absence and Workplace Health Survey.
 
 
Despite the introduction of the new “fit note” in 2010, the rate of absence last year was marginally higher than in 2009, when employees averaged 6.4 sick days, the lowest rate since the survey began in 1987. The 190 million days cost employers £17bn, including over £2.7bn from 30.4 million days of non-genuine sickness absence – so-called “sickies”. This does not include the other indirect costs of absence, like lower customer service and lost productivity. (WCxKit)
 
 
This year’s survey is the first since the launch of the fit note – the new medical certificate focused on what people can do rather than what they can’t, designed to aid returns to work and reduce absence costs. Despite strong support for the initiative, employers have been disappointed by their experience so far: 66% of firms said that it had not yet helped their rehabilitation policy, and 71% were not confident that GPs were using the fit note differently from the old sick note.
 
 
Katja Hall, CBI Chief Policy Director, noted, “There’s been no let up in the cost of absence to the UK economy, which runs into billions of pounds a year. Although many organizations have been successful in bringing down levels of absence, the gap between the best and worst has widened.
 
 
The substantial costs of absence to the economy put a premium on managing longer-term absence well. The fit note is a great initiative, which could play an important role in helping people back to work and stopping them slide into long-term absence. But employers are far from convinced that the scheme is working properly and don’t think GPs are getting the necessary training.
 
 
The launch of the electronic fit note should be an ideal opportunity for the Department of Work and Pensions to extend the reach of its training program and address GPs’ engagement. There can be no room for complacency in addressing the so-called sick note culture.”
 
 
On the cost of “sickies”, Hall added, “Sadly, more days were lost to non-genuine absence than in 2009 and the cost of these bogus sick days is over £2.7bn a year. Sickies are unfair on colleagues and damage employers' competitiveness at a critical point in the recovery.”
 
 
Employees in the public sector took more sick days than those in the private sector, an average of 8.1 days a year compared with 5.9 days. This represents an improvement on last year’s average of 8.3 days and a marked improvement since 2007’s average of 9 days. Far more absence in the public sector is long-term than in the private sector, and reducing this will be key to reaching private sector levels. (WCxKit)
 
 
The CBI estimates that if the public sector could reach private sector absence levels, it would save the taxpayer around £5bn by 2015-16. The cost of absence is much higher in the public sector – a median of £1040 compared with £710 in the private sector, or a difference of 46%.
 
 
Author Robert Elliott, executive vice president, Amaxx Risks Solutions, Inc. has worked successfully for 20 years with many industries to reduce Workers Compensation costs, including airlines, healthcare, printing/publishing, pharmaceuticals, retail, hospitality and manufacturing. See www.LowerWC.com for more information. Contact:Info@ReduceYourWorkersComp.com or 860-553-6604.

 
Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker or agent about workers comp issues.
 
©2011 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law. If you would like permission to reprint this material, contact Info@ReduceYourWorkersComp.com.

Employee Absences Decrease as Economy Sinks

The economic downturn and rising jobless rate appear to have put a brake on employee absences, according to a recent survey.
 
Rates of employee absences through 2009 are at the lowest recorded since 1985, the year legal and business publisher Bureau of National Affairs (BNA) began its quarterly survey of employers.
 
Dropping below the 2008 low of 0.9 percent of scheduled worker days per month, the median absence rate in 2009 averaged 0.7 percent. Absence rates have declined consistently since 2005, when they averaged 1.5 percent of scheduled worker days.
 
Year-over- year absence rates declined in nonbusiness and manufacturing organizations, but were stable in nonmanufacturing concerns. Absences tended to be lower in smaller than in larger organizations.
 
Regionally, median monthly absence rates from 2008 to 2009 fell two-tenths of a point in the Northeast (from 0.9 percent to 0.7 percent) and three-tenths of a point in the North Central states (from 1.1 percent to 0.8 percent). There was no change in the South (0.7 percent), while in the West, median monthly absence rates increased only marginally, from 1.1 percent to 1.2 percent.
 
Similarly, employee turnover (voluntary median monthly separation rates excluding layoffs, reductions-in-force, and departures of temporary staff), in tandem with slowing economic growth and rising rates of unemployment, has plunged from 1.0 percent of employers’ workforces per month in 2008 to 0. percent in 2009. (workersxzcompxzkit)
 
The weakening economy and job market appears to discourage employees from seeking other job opportunities, as turnover rates shrank for employers in every category of industry and workforce size, and in every region of the country.

Author Robert Elliott, executive vice president, Amaxx Risks Solutions, Inc. has worked successfully for 20 years with many industries to reduce Workers' Compensation costs, including airlines, health care, manufacturing, printing/publishing, pharmaceuticals, retail, hospitality and manufacturing. He can be contacted at: Robert_Elliott@ReduceYourWorkersComp.com.

Podcast/Webcast: Occupational Health Strategies
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WC Calculator: http://www.reduceyourworkerscomp.com/calculator.php


Do not use this information without independent verification. All state laws vary. You should consult with your insurance broker or agent about workers' comp issues.
 
©2010 Amaxx Risk Solutions, Inc. All rights reserved under International Copyright Law. If you would like permission to reprint this material, contact Info@ ReduceYourWorkersComp.com.

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