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Hearing Loss and Tinnitis Claims - Maryland Workers' Compensation Law

Monday, September 19, 2016

By Clifford B. Sobin, Esq.


Occupational Deafness claims under Maryland Workers Compensation generally involve two different medical problems. The first is actual inability to hear sounds. This is referred to as hearing loss. The second often shows up as "ringing in the ears" and frequently is caused by tinnitus. Despite the fact that they both impact your ability to hear and understand what other say, they are treated differently by Maryland law.

This blog entry is part of a three part series.

  • This blog post discusses hearing loss.
  • My next blog will cover tinnitus.
  • The third in this series will talk be about money you may receive if your case is found compensable and the importance of filing a claim due to the potential future expense of hearing aids.

How Much Hearing Loss Do You need to File a Claim?

Unfortunately, not all hearing loss that you may have is covered. Typically, occupational hearing loss first appears at the higher frequencies. If your employer provides hearing tests, as is the case with many fire fighters, the records will include a chart that summarizes the testing results. The same is the case if you go to your private physician.

Usually, if you have hearing loss it will first show up at the higher frequencies; between 4,000 and 6,000 hertz. Although that type of loss is annoying because it means you have difficulty hearing high pitched sounds and perhaps voices on the telephone – it is not covered under Maryland Worker's Compensation law. Only frequency loss in the 500 to 3,000 range is covered. And then, only if the average is more than 25 decibels of loss and your age was less than fifty when you were last exposed to noise (your hearing tests will show the loss at 500, 1000, 2000, and 3000 herz).

If you were older than fifty when last exposed to loud noise on your job, the average goes up by one half decibel for each year. Therefore, if your last exposure was at age 54, you need more than an average of 27 decibels of loss.

Which Employer Pays?

Generally, the last employer you worked for when last exposed to loud noise is responsible for paying your hearing loss claim if you worked there for at least ninety days. However, that employer has the right to try to lay off some of the responsibility to pay you if they can prove your prior employers caused some of your hearing loss. But that is their problem, not yours.

However, if you worked for more than one employer at the same time of your last noise exposure, and you were exposed to loud noise while working for both, then things get a little bit more complicated. Frequently, both employers will be added to your Workers' Compensation claim and both will share the responsibility to pay you.

How Long Do You have To File a Hearing Loss Claim?

The easy answer is two years, but two years from what? To be on the safe side you should seek legal advice as soon as you think you are suffering from hearing loss. It is a simple matter for your attorney to review your medical records and determine if it is time to consider filing a claim. I usually ask my clients to forward me their last hearing test and then I tell them in a quick telephone call if they should move forward. If you are curious for yourself, I invite you to contact me. There is no charge for me reviewing the records.

But what if it has been more than two years since you first have had tests showing hearing loss? The simple answer is … it's complicated. There is an appellate case that said an employee filed his claim too late because he waited more than two years from when he was told by his doctor that he had hearing loss caused by his job and – this is important – the test showed a level of hearing loss that was covered under Maryland law. The bottom line is the following factors matter:

  • When were you advised that you have hearing loss?
  • What were the test results when you were told?
  • Did your physician say it was occupationally related?
  • Has your employment changed since your last test and has your hearing worsened in the new employment?
  • Has it been more than two years since you first have had hearing test that is compensable under Maryland law?

Unfortunately, as you might guess by now, I can't provide you with a definite answer for you to be sure how long you have to file a claim. To what extent the factors above make a difference is very fact specific. Only an attorney can make an informed decision and provide you with the proper advice customized to you.


Medical Treatment Rights Under Maryland Workers’ Compensation Law For Out Of State Treatment

Monday, September 19, 2016

By Clifford B. Sobin, Esq.

 

Last month I discussed medical treatment rights stemming from a compensable Maryland Workers’ Compensation claim. Since medical costs are controlled by the Maryland Workers’ Compensation system, you never have to pay anything for treatment required for injuries sustained as part of your compensable claim – with one catch – the treatment must be in Maryland.

Medical bills of health care providers who provide treatment outside of Maryland are not controlled by the Maryland Workers’ Compensation system. Therefore, in those circumstances you may have to pay a portion of the costs for treatment you need for injuries sustained as part of your compensable claim. The amount you will pay is the difference between what the medical provider charges and the amount the Maryland fee schedule requires employer/insurers to pay.

What should you do?

Most of the time obtaining treatment is not a problem. Since many Workers’ Compensation systems have fee schedules, as does Medicare and private insurance plans, health care providers will often agree to reduce their charge to the Maryland fee schedule rate.

However, you must ask before the treatment starts, not after the bill arrives! Otherwise it may be too late.

It has been my experience, with few exceptions, that out of state health care providers accept the fee schedule. When they refuse, it has also been my experience that the Maryland Workers’ Compensation Commission will not order the employer/insurer to pay more than the fee schedule unless the treatment required is unavailable in Maryland and is clearly required by the claimant this does not mean a new speculative procedure not yet approved in the United States).

An additional problem is presented when an injured worker receives medical treatment outside the Unites States. This is because it is the injured worker’s responsibility to provide employer/insurers all medical reports and bills. The bills must be coded in a certain manner and the reports must be in English. The burden to provide documentation is not an insurmountable stumbling block, but it is a frustrating one that often causes extensive delays when the treatment is not in the United States.

Injuries From Prescription Related Side Effects For Firefighters

Tuesday, April 26, 2016

Over the years, I have represented thousands of you for claims arising out of work related, as well as non-work related, injuries and/or diseases. Unfortunately, not only have you had to worry about the injuries and the diseases themselves, other concerns have arisen besides the dangers of your profession. Recently, many of the treatments for these problems have been declared dangerous and life threatening.

Side Effects From Xarelto and Other Prescription Meds

For instance many individuals have been prescribed Xarelto as a blood thinner. Xarelto, as you may already know, has been the subject of lawsuits because it has been found that Xarelto can lead to uncontrollable internal bleeding and other serious complications, including heart problems and/or strokes. In addition, for those who have work related or even non-work related problems or diseases, manufacturers of medical devices and IVC, have recalled their products. Inferior Vena Cava Filters (known as “IVCs”) are designed to prevent life threatening pulmonary embolisms. Some of these filter failures have resulted in deaths.

Furthermore, a well-known consequence of hypertension is a loss of potency. The FDA alerted consumers and healthcare providers that a small number of men have lost eyesight after taking Viagra, Cialis or Levitra.

How We Can Help You, Or, Someone You Care About

Berman, Sobin Gross, Feldman, and Darby, LLP has been at the forefront in resolving the cases involving unsafe drugs and medical devices and protecting injured workers, and their families. If you believe you have been harmed by any of these products or by such products as Pinnacle DuPey® Hip Replacements, Taxotere®, or Essure®, please contact me at (301) 670-7030. In the meantime, stay safe.

By Ken Berman

Benefits For Burns, Scars & Disfigurements

Friday, March 04, 2016

Maryland Workers’ Compensation law requires the Employer/Insurer of a worker who is burned, scarred or disfigured while performing his/her job to pay to that worker, compensation benefits. This includes, and is especially relevant to, fire fighters.

A fire fighter who is burned, disfigured or scarred while either fighting a fire or performing any other aspect of his job has the right to receive $343.00 per week (the 2016 rate) up to a maximum of 156 weeks for any such disfigurement, burn or scar. As in many other requirements of the Workers’ Compensation law, fault is not a factor, however the employee has 2 years to file such a claim after the disfigurement or scarring occurs.

If you have been burned or incurred any scarring in the last 2 years contact us immediately to process the claim and obtain the benefits that are rightfully yours.

Conclusion

The laws governing workers’ compensation are complex. However, the system is designed to benefit an injured worker. An attorney can only charge if recovery is made. If you have a question regarding anything in the outlines, or any other questions, please feel free to contact us at Berman Sobin Gross, Feldman & Darby. Our telephone number is 301-670-7030 and our toll free number is 800-827-COMP.

By Ken Berman

Advice For The Apprehensive Injured Worker

Wednesday, November 11, 2015

A few times a week I get a call from an injured worker who is considering filing a workers’ compensation claim with the Maryland Workers’ Compensation Commission but is concerned about the repercussions that may take place after filing their claim.

While it is understandable, and in certain circumstances a very real concern that an employer may retaliate against an injured worker after a claim is filed, if you are injured on the job you must understand what rights you may be giving up if you don’t file a workers’ compensation claim. Often times you may be giving up more by deciding not to file a claim than you would be even in the worst case scenario for employer retaliation – termination. (It should be noted that Maryland is an “at-will” employment state, meaning an employer can fire an employee for any non-illegal reason. However it is against Maryland law to fire an employee for filing a workers’ compensation claim). Those who have been lucky enough to avoid the workers’ compensation process understandably may have little to no knowledge of what benefits may be available to them through Maryland’s workers’ compensation laws. The following paragraphs will detail the rights potentially available to injured workers in Maryland who are successful in filing their workers’ compensation claim. (As a quick aside, it is of utmost importance to understand that filling out a report of injury for your employer is NOT filing a claim with the Maryland Workers’ Compensation Commission. If a claim is not properly filed you may be forfeiting your rights. It is important to consult legal counsel to ensure proper filing).

By failing to file a claim you may be giving up compensation at 2/3s of your pre-taxed wages for the period of time you are unable to work while you recover from your work injury. Often times this means exhausting your hard earned personal, vacation and/or sick leave when your employer or its insurer is the legally responsible for paying your wages for each day missed – and doing so without tapping into your personally accrued leave time. This benefit becomes especially important if you are separated from your employment. This is because the payment of workers’ compensation leave benefits that you are entitled to while you are unable to work as a result of your work injury has no correlation to your employment itself. Whether you are still employed or have been separated from employment, you are still entitled to compensation if you cannot do your job and your doctor agrees that you must be out of work.

Compensation for time out of work is important – everyone has bills to pay – and the money received for lost time from work can help to make sure you don’t fall behind while you work to get back on the job. However, the best benefit in Maryland’s workers’ compensation law is the payment of medical treatment necessitated by your work injury. Maryland is unique in that you have the right, as an injured worker, to seek treatment with a doctor of your choice. And most important of all, there is no time limitation on your ability to seek treatment as a result of a work injury. (The right to fight for treatment never expires once a claim has been accepted, however, there are no guarantees your employer or their insurer will authorize the treatment you wish to have – yet another good reason to consult with a legal professional). If you fail to file a claim with the Workers’ Compensation Commission, often times the insurance adjuster will take longer to authorize treatment as there is no real motivation to do so. Further, if the insurance company decides to deny your treatment you will have no means to force them to pay for the treatment your doctor is recommending. This leaves you with the responsibility of convincing your own insurance company to pay for your treatment, or worse yet, paying for your treatment out of pocket. By successfully filing a claim, you’re guaranteeing at least the right to fight for your employer to pay for the treatment you need to get you better and back to work.

Compensation for permanent disability is the last main benefit available to those who are successful in filing a workers’ compensation claim. Often times the money received for an individual’s permanent disability does not truly compensate him/her for the affect their injury has had on their life – especially with more serious injuries. However, some compensation is certainly better than receiving no compensation at all. By failing to file a claim, you forgo this right altogether.

You work hard at your job every day, giving up precious time with your family to help further your companies’ goals. If you get hurt while on the job you owe it to yourself to protect both you and your family by filing a claim. You should not have to pay out of your own pocket for medical treatment, struggle to make your bills because you are incapable of earning an income, or worse yet be forced to suffer from a life altering disability without receiving any assistance from your employer and their insurer to get you back on your feet.

So if you get hurt on the job – protect yourself and your family by filing your claim. And if you’re concerned about the potential repercussions of doing so, consult with legal counsel to make sure you understand not just what problems may arise if you do file your claim, but what problems may arise if you don’t.

By Charles Schultz, Esq.

Correctional Officers And Hypertension: Protect Your Rights

Tuesday, September 29, 2015

Being a correctional officer is one of the most dangerous and stressful jobs in the world. Think about what these women and men do every day. They walk through prison gates; the doors are locked BEHIND them, and are asked to protect us from the most dangerous criminals in Maryland. They are not carrying firearms and are wearing very little protection. Correctional officers know the risk and despite that, show up every day for work and protect the public. In turn, the State of Maryland does not provide them with as many workers’ compensation protections as they could.Correctional officers are on the front lines of public safety in Maryland. They stand side by side with police and fire to provide safety to the public. Yet the law does not afford them the same protections as police and fire. In Maryland, and throughout the country, the law recognizes that police officers and firefighters have a higher risk of developing hypertension and heart disease. This is a direct result of the high stress nature of being a police officer and firefighter. The law presumes that if a police officer or firefighter develops hypertension, it’s presumed to have been caused by the stress of their job. This is backed up by research. The presumption itself is vital because the workers’ compensation insurance company has the burden to prove that the hypertension was caused by something other than the stress of the job. In other workers’ compensation cases, the burden is on the injured worker to prove the injuries were caused by the accident or the in the case of an occupation disease, the disease was caused by the nature of the employment.

Why doesn’t the law provide correctional officers the same protection as police and fire? Think about what correctional officers face every day. The threat of assault is constant; they have to be on high alert from the moment they walk in the prison. Is being surrounded by violent criminals forty hours a week just as stressful as being a police officer and firefighter? And when you think about public safety, people often fail to consider that correctional officers are the last line of defense, and provide just as much safety to the public as police or fire. There have been bills introduced in the last two Legislative sessions to provide Maryland correctional officers the same protections as police and fire and neither has been enacted. Two sessions ago during the testimony before Senate, representatives from the workers’ compensation insurance industry actually testified that correctional officers do not protect the public, and that’s why legislators should vote down the bill!

Some jurisdictions in Maryland do recognized that correctional officers have the same increased risk of hypertension. Both Montgomery and Prince George’s counties treat their correctional officers the same as their police and firefighters. If a Montgomery County or Prince George’s County correctional officer develops hypertension, the law presumes it’s caused by the stress of their employment and they are entitled to workers’ compensation benefits, but if a correctional officer in a State of Maryland facility develops hypertension, they do not have the same protection. How can this be? The worst of the worst are housed in State of Maryland facilities. How can State of Maryland correctional officers not face the same, if not more stress, as a Prince Georges’ or Montgomery County correctional officers?

Despite this inherent unfairness, correctional officers throughout the state STILL have the right to file hypertension claims. Just because they don’t have the presumption does not mean they cannot fight for their rights. We are currently fighting for the rights of correctional officers who have hypertension despite the lack of a presumption bill, and we will continue to do so. If you do have a hypertension and are a correctional officer, make sure you protect your rights by filing a workers’ compensation claim. Don’t wait for the Legislature to protect your rights for you.

By Jason Shultz, Esq.

Hearing Loss And Tinnitis Claims – Maryland Workers’ Compensation Law

Thursday, October 10, 2013

Occupational Deafness claims under Maryland Workers Compensation generally involve two different medical problems. The first is actual inability to hear sounds. This is referred to as hearing loss. The second often shows up as “ringing in the ears” and frequently is caused by tinnitus. Despite the fact that they both impact your ability to hear and understand what other say, they are treated differently by Maryland law.

This blog entry is part of a three part series.

  • This blog post discusses hearing loss.
  • My next blog will cover tinnitus.
  • The third in this series will talk be about money you may receive if your case is found compensable and the importance of filing a claim due to the potential future expense of hearing aids.

How Much Hearing Loss Do You need to File a Claim?

Unfortunately, not all hearing loss that you may have is covered. Typically, occupational hearing loss first appears at the higher frequencies. If your employer provides hearing tests, as is the case with many fire fighters, the records will include a chart that summarizes the testing results. The same is the case if you go to your private physician.

Usually, if you have hearing loss it will first show up at the higher frequencies; between 4,000 and 6,000 hertz. Although that type of loss is annoying because it means you have difficulty hearing high pitched sounds and perhaps voices on the telephone – it is not covered under Maryland Worker’s Compensation law. Only frequency loss in the 500 to 3,000 range is covered. And then, only if the average is more than 25 decibels of loss and your age was less than fifty when you were last exposed to noise (your hearing tests will show the loss at 500, 1000, 2000, and 3000 hertz).

If you were older than fifty when last exposed to loud noise on your job, the average goes up by one half decibel for each year. Therefore, if your last exposure was at age 54, you need more than an average of 27 decibels of loss.

Which Employer Pays?

Generally, the last employer you worked for when last exposed to loud noise is responsible for paying your hearing loss claim if you worked there for at least ninety days. However, that employer has the right to try to lay off some of the responsibility to pay you if they can prove your prior employers caused some of your hearing loss. But that is their problem, not yours.

However, if you worked for more than one employer at the same time of your last noise exposure, and you were exposed to loud noise while working for both, then things get a little bit more complicated. Frequently, both employers will be added to your Workers’ Compensation claim and both will share the responsibility to pay you.

How Long Do You have To File a Hearing Loss Claim?

The easy answer is two years, but two years from what? To be on the safe side you should seek legal advice as soon as you think you are suffering from hearing loss. It is a simple matter for your attorney to review your medical records and determine if it is time to consider filing a claim. I usually ask my clients to forward me their last hearing test and then I tell them in a quick telephone call if they should move forward. If you are curious for yourself, I invite you to contact me. There is no charge for me reviewing the records.

But what if it has been more than two years since you first have had tests showing hearing loss? The simple answer is … it’s complicated. There is an appellate case that said an employee filed his claim too late because he waited more than two years from when he was told by his doctor that he had hearing loss caused by his job and – this is important – the test showed a level of hearing loss that was covered under Maryland law. The bottom line is the following factors matter:

  • When were you advised that you have hearing loss?
  • What were the test results when you were told?
  • Did your physician say it was occupationally related?
  • Has your employment changed since your last test and has your hearing worsened in the new employment?
  • Has it been more than two years since you first have had hearing test that is compensable under Maryland law?

Unfortunately, as you might guess by now, I can’t provide you with a definite answer for you to be sure how long you have to file a claim. To what extent the factors above make a difference is very fact specific. Only an attorney can make an informed decision and provide you with the proper advice customized to you.

By Clifford B. Sobin, Esq.

The First Week After Your Maryland Workers’ Compensation Injury

Wednesday, June 12, 2013

What you do during the first week after being injured on the job will set the tone for the rest of your claim. It is the most important time. You must:

  • Report the injury to your employer.
  • Get medical treatment as soon as possible. Don’t let several days pass.
  • Give an accurate history of the injury to your medical provider.
  • Don’t speak to the insurance company unless you are sure you are not going to get an attorney (a decision that almost always is a bad one).
  • If you want an attorney, choose one who will guide you, educate you, and that you trust. If the conversation is only about money, consider choosing another attorney.
  • File a Workers’ Compensation claim.
  • Choose a doctor for follow up care and obtain authorization to go.
  • Decide if you are going to speak to a nurse assigned by the insurance company to your case.

If you make the wrong decisions, you might make it difficult to win your case. The insurance company may deny your claim. What you say or do in the first days after you are injured matters once you are in front of a Commissioner. Even if the insurance company pays benefits in the beginning, when the inevitable disagreement with the insurance company occurs, you will not be in a position to obtain a speedy hearing in front of the Workers’ Compensation Commission if a claim was not previously filed appropriately.

What You Do Matters

You should report your injury to your employer immediately after it occurs and at worst not later than the next day. Never wait until Monday to report an injury that occurred on Friday. If your injury was not witnessed by anybody else, you risk it will be assumed you hurt yourself over the weekend and are now lying.

Always get prompt medical treatment and tell the doctor what happened. If for some reason you did not report the injury to your employer but told the emergency room you were injured on the job earlier that day that will usually be enough to win your case if the insurance company contests it. Furthermore, by getting the treatment immediately:

  • You get the care you need when you need it.
  • You protect yourself from the insurer arguing you had a new injury between your job related injury and the medical treatment you are now receiving.

You should not speak to the insurance company without having hiring, or at least meeting with, an attorney. Workers’ compensation is an extremely complex area of law. The insurance adjuster is experienced in finding reasons not to accept a claim. You are not experienced with dealing with insurance adjusters looking for reasons not to pay you. Your desire to be helpful to the adjuster may be hurtful to you. Instead, you should have an attorney control all communications with the insurer.

You should also have the assistance of an attorney when your Workers’ Compensation claim form is filed. It matters what is written on the form. It matters even more if you have not reported all the details of your injury to the employer or if your doctor did not write down the correct history of the injury you provided. The average weekly wage you write in the claim form matters as well. It is up to the insurance company to dispute whatever you claim. If you state too low a number because you are not clear on the law, will the insurance company correct it? You already know the answer to that.

Your choice of medical provider can have a significant impact on the future of your claim. Some doctors are better than others. Some injuries require specific medical specialties. Your attorney can guide you through this unfamiliar territory.

Frequently, insurance companies assign nurses to manage the medical aspects of compensation claims. They will attempt to contact you, your doctor and be present at your medical appointments. They are often beneficial in catastrophic cases. However, the value of having them versus the risk they present is an issue, especially with less severe injuries. The insurance company will obtain information through their involvement that they may otherwise never know. Also, nurses often pressure health care providers to do things that you might not welcome. That is why most attorneys place stringent ground rules on their involvement. Furthermore, experienced attorneys have a much greater sense of which nurses can be trusted and which nurses cannot. You should never speak to one without the assistance of counsel.

The bottom line is that the first week after an injury is the scariest and most dangerous time for you. The injury is scary because of the pain it is causing you and your fears of how it will impact your future. It is also dangerous because your actions, non-actions, statements, and non-statements may haunt you throughout the rest of your claim.

By Clifford B. Sobin, Esq.

10 Things You Need To Know About IMEs (Independent Medical Evaluations)

Thursday, November 15, 2012

The insurance company has the right to send you to a doctor of their choice for a medical opinion. This doctor is not going to provide you with any treatment or become your doctor, but rather only give an opinion. Here are 10 things you need to know:

  1. The IME is for the benefit of the insurance company, not you.
  2. The doctor is not required to keep anything you say in confidence; everything you tell him/her, or fail to tell him, will be contained in his report.
  3. Contrary to the letter you receive from the insurance company, you are not required to bring any test results or medical records with you. It is the insurance company’s responsibility to provide their doctor with the reports they want him to review.
  4. The IME doctor and his staff will watch how you walk, move, whether you bend down to tie your shoes or pick up a piece of paper you might have dropped, or how you remove a piece of clothing, and they will compare it to the complaints you tell them about during the exam and what is contained in your medical records, so be consistent. And never lie or exaggerate, but rather be specific about what pain you feel or limitations you experience.
  5. You should tell the doctor about any other accidents you were involved in, whether they happened before or after the work-related injury. Failing to inform the doctor of a prior accident hurts your credibility and makes it look like you are hiding information.
  6. Do not miss your appointment or arrive late. This could result in the insurance company terminating benefits, such as your lost wages, and the Workers’ Compensation Commission could order you to pay for the missed appointment.
  7. The doctor does not have the right to perform any invasive tests on you, such as xrays, injections or EMG/nerve conduction studies.
  8. A female should never be alone in the examination room with a male doctor, so typically the doctor will have a member of his staff in the room during the examination for your safety.
  9. The examination will likely be very short (a few minutes), so it’s important that you be as comprehensive as possible about the complaints you have.
  10. The day of the IME is typically when insurance companies hire a private investigator to video tape you in hopes of “catching you” doing something that is inconsistent with what you tell the doctor or which reveals that you are capable to working. You should be consistent at all times and with all doctors.

By Ken Berman

Medical Treatment Rights Under Maryland Workers’ Compensation Law For Out Of State Treatment

Monday, September 24, 2012

Last month I discussed medical treatment rights stemming from a compensable Maryland Workers’ Compensation claim. Since medical costs are controlled by the Maryland Workers’ Compensation system, you never have to pay anything for treatment required for injuries sustained as part of your compensable claim – with one catch – the treatment must be in Maryland.

Medical bills of health care providers who provide treatment outside of Maryland are not controlled by the Maryland Workers’ Compensation system. Therefore, in those circumstances you may have to pay a portion of the costs for treatment you need for injuries sustained as part of your compensable claim. The amount you will pay is the difference between what the medical provider charges and the amount the Maryland fee schedule requires employer/insurers to pay.

What should you do?

Most of the time obtaining treatment is not a problem. Since many Workers’ Compensation systems have fee schedules, as does Medicare and private insurance plans, health care providers will often agree to reduce their charge to the Maryland fee schedule rate.

However, you must ask before the treatment starts, not after the bill arrives! Otherwise it may be too late.

It has been my experience, with few exceptions, that out of state health care providers accept the fee schedule. When they refuse, it has also been my experience that the Maryland Workers’ Compensation Commission will not order the employer/insurer to pay more than the fee schedule unless the treatment required is unavailable in Maryland and is clearly required by the claimant this does not mean a new speculative procedure not yet approved in the United States.

An additional problem is presented when an injured worker receives medical treatment outside the United States. This is because it is the injured worker’s responsibility to provide employer/insurers all medical reports and bills. The bills must be coded in a certain manner and the reports must be in English. The burden to provide documentation is not an insurmountable stumbling block, but it is a frustrating one that often causes extensive delays when the treatment is not in the United States.

By Clifford B. Sobin, Esq.

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