Summary
The Supreme Court of Pennsylvania considered whether “compensation” under Section 314(a) of the Pennsylvania Workers’ Compensation Act includes medical benefits as well as wage-loss benefits. The court held that the term need not always include medical benefits, but may include them in appropriate circumstances, and affirmed the Commonwealth Court’s decision allowing a workers’ compensation judge discretion to suspend wage-loss benefits alone or both wage-loss and medical benefits when an employee unjustifiably refuses a compelled medical examination.
Topics
Practice areas
Questions Presented
- Whether the term 'compensation' in section 314(a) of the Pennsylvania Workers' Compensation Act must include medical benefits as well as wage-loss benefits.
- Whether a workers' compensation judge has discretion under section 314(a) to suspend wage-loss benefits alone or both wage-loss and medical benefits when a claimant unjustifiably refuses or neglects to attend a court-ordered physical examination or expert interview.
Holdings
- The term 'compensation' in section 314(a) need not always include medical benefits as well as wage-loss benefits. Its meaning depends on the statutory context, and in the proper circumstances it may include both types of benefits.
- A workers' compensation judge has discretion under section 314(a) to suspend wage-loss benefits alone or to suspend both wage-loss and medical benefits when a claimant, without reasonable cause or excuse, refuses or neglects to comply with an order to attend a physical examination or expert interview.
Key quotations
“We hold that “compensation,” as used in Section 314(a) need not always include medical expenses, and we accordingly affirm the Commonwealth Court.” (39 A.3d at 298)
“That is, in the proper circumstances, “compensation” under Section 314(a) may include medical benefits as well as wage loss benefits.” (39 A.3d at 294)
Factual background
Quila Givner suffered a work-related injury while employed by Giant Eagle and received partial-disability wage-loss benefits and related medical benefits. After Giant Eagle requested a physical examination under section 314(a), a WCJ ordered Givner to attend the examination, but she failed to do so without establishing reasonable cause or excuse. The WCJ suspended her wage-loss benefits until she submitted to an examination, but did not suspend her medical benefits.
Procedural history
After Givner failed to attend a workers' compensation judge-ordered physical examination, the WCJ suspended her wage-loss benefits until she submitted to an examination. The WCAB affirmed, and the Commonwealth Court affirmed in a published opinion. The Supreme Court of Pennsylvania granted review on whether section 314(a)'s reference to deprivation of 'compensation' permits suspension of medical benefits as well as wage-loss benefits.