10-16-2017; Will The 2017 WC Deforms Return from the Dead to Kill New and Existing IL Businesses?; In IL WC, It Is Not Just Getting the Emails, It is Opening Them and more

Synopsis: Illinois General Assembly Returns in Nine Days for their Fall Veto Session—Will Their 2017 Workers’ Comp “Deforms” Return from the Dead to Kill New and Existing IL Business/Gov’t?

 

Editor’s comment: Earlier this year, Governor Bruce Rauner vetoed a number of bills were certain to make Illinois already troubled financial canoe even tipsier. Many of the bills were certain to increase the cost of doing business in our state. If they were all to become law, we are certain these bills would drive business from the state and pose a terrible blow to Illinois being able to compete for high-paying jobs with good benefits. I salute our plucky Governor's willingness to join with business groups like the Illinois State Chamber of Commerce and others while getting pressure to sign these bills from organized labor and other special interest groups who seem bent on destroying Illinois' jobs climate.

 

The General Assembly returns to Springfield for the veto session the week of October 23rd and the week of November 6th. The veto session likely will demonstrate the strength of the Governor's relationships with Republican lawmakers, especially Illinois House Republicans. With the friction created between the Governor over the budget deadlock and tax increase override vote, Governor Rauner will lobby and then rely on House Republicans to sustain his important vetoes. To override the vetoes, Democrats will need 71 votes in the House and 36 votes in the Senate. The current political makeup of the Illinois House is 67 Democrats and 51 Republicans. The Senate has 37 Democrats to 22 Republicans.

 

The two Work Comp Bills where a legislative override of the Governor’s veto might happen are:

 

·         HB 2525, sponsored by Rep. Jay Hoffman (D-Swansea)/Sen. Kwame Raoul (D-Chicago). This nutty bill is being promoted by the House & Senate Democrats as workers' compensation “reform.”

 

o   I consider it a “fake” bill that was created to counter the less-than-brilliant WC proposals of Governor Rauner in his “Turnaround Agenda.”

o   Now that the “Turnaround Agenda” basically disappeared, we hope this silly bill will similarly disappear but you never know.

o   The bills codifies very poor WC case law for "causation" and "traveling employee."

o   This bill, if the Gov’s veto is overridden, may expand workers’ comp coverage drastically, as it would lock IL employers into a poorly thought-out court-expanded liability that was later rejected by the IL Supreme Court.

o   In addition, it prevents employers from being able to achieve a change in case law from future courts. Some WC benefit relief is included but is far outweighed by increased regulation and litigation.

 

·         HB2622,  sponsored by Rep. Laura Fine (D-Glenview/Biss). This legislation uses employer and insurer tax dollars to capitalize the creation of a state-established, mutual Workers’ Comp insurance company to compete with the over 300 insurers that already provide hotly competitive workers' compensation coverage.

 

o   The $10 million of startup money are tax dollars that currently go to pay for the operations of the IL Workers' Compensation Commission.

o   No one knows how the IWCC would operate with an immediate and gaping $10M hole in their $30M budget.

o   The legislation provides the start-up funds are supposed to be a "loan" to be paid back by the new State-owned carrier with interest to the IWCC!

o   Given the hilarious track record of Illinois government, it is difficult to believe the loan would be paid by this start-up company.

o   Further, given the laughingly poor management proclivities of Illinois gov’t leadership, it is impossible to imagine this tiny insurance carrier could possibly compete with the international giants of the insurance industry.

o   If the new insurance company floundered, one has to wonder if they would again tap into the IWCC funding, further jeopardizing important administrative functions in adjudicating benefits for injured workers.

o   The whole silly concept is based on an ITLA-driven theory that all the major U.S. insurance carriers somehow “hide” box-car profits but only in this single state.

If the vetoes of either IL WC bill are overridden, rest assured the IL WC system is going to be steeped in confusion and chaos for some time to come. WC premiums/benefits and costs may literally skyrocket. The administration of our system of WC justice may be wildly changed.

 

Please keep your fingers crossed that our General Assembly doesn’t make a mess of things while Amazon is considering moving its second headquarters here.

 

Watch this space for news on this cliffhanger. We appreciate your thoughts and comments. Please post them on our award-winning blog.

 

Synopsis: In IL WC, It Is Not Just Getting the Emails That May Be Important, It Is Opening Them!!

 

Editor’s comment: We saw a recent IWCC ruling of some importance on the issue of managing emails from this administrative body. The facts are fairly clear. On party filed a Petition for Review of the Arbitrator’s decision.

 

Both parties agreed to waive receipt of the Arbitrator’s decision by certified mail and consented to receive the ruling via email. Both parties agreed their email addresses were accurate on the Request for Hearing form or “stip sheet.” The Arbitrator’s decision was filed on Feb. 2, 2016 and forwarded to both sides via email on Feb. 3, 2016. The appealing party did not file the requisite Petition for Review until March 31, 2016, well after the 30-day period required under Section 19(b) of the IL WC Act. On the Petition for Review the appealing party indicated the decision was filed on Feb. 2, 2016 but received on March 23, 2016.

 

Pursuant to IWCC procedure, decisions are emailed with a delivery receipt and read receipt requested. The delivery receipt is generated automatically when the email is successfully transmitted to the recipient’s email address. The read receipt is generated when the email is opened. The Commission notes it is possible for the read receipt to be manually prevented by the receiving party. In this claim, the non-appealing party sent the read receipt on the day the email was sent or Feb. 3, 2016. The appealing party’s email system didn’t send the read receipt until March 24, 2016.

 

The appealing party claimed the Arbitrator’s decision was emailed to an attorney who was no longer at the firm and the departing attorney’s email wasn’t monitored by anyone at the law office. Without citing anything in support, the appealing party asserted their supposed understanding that an emailed decision was not considered “received” until receipt occurs by opening the email.

 

The IWCC’s ruling indicates what happened with this appeal would be synonymous with someone getting a certified letter via USPS and then choosing not to open it for a month or more. The IWCC’s unanimous ruling indicated the appealing party’s law firm had an affirmative duty to monitor and open emails sent to all attorneys at the firm. If there was a change, the parties also had an affirmative duty to advise the Arbitrator of the change in email address to insure decisions are properly relayed to the parties of record.

 

The Commission ruling said: “To find otherwise would allow too much opportunity for the 30-day deadline to be subverted by simply waiting indefinitely to read any emails from the Commission.” The Petition for Review was dismissed for lack of jurisdiction.

 

I strongly salute this ruling. I wanted to report it to insure parties on all sides of any IWCC claim are aware of it. The matter may be further appealed and this article is not intended to effect that outcome in any way.

 

We appreciate your thoughts and comments. Please post them on our award-winning blog.

 

10-10-2017; Odd Effort to Slash Claimant Attorney’s Fees on $300K+ Settlement Rebuffed by Courts; Shiny New Website for IL WC Commission, as Part of E-Filing Efforts and more

Synopsis: Effort to Slash Claimant Attorney’s Fees on $300K+ Settlement Smoothly Rebuffed by IWCC and IL Courts.

Editor’s comment: We agree with this outcome and dislike these sorts of shenanigans. This claim involved three of Illinois’ more prominent and successful Claimant firms that KCB&A respects as solid advocates for the injured workers they diligently represent. The firms handled the work comp aspect of a personal injury claim and at settlement, Claimant and current counsel tried to basically cut them all out of any fees for their work. While we are a defense firm, we always struggle to see solid Claimant firms do lots of work in claims with combined WC and PI issues to then have Claimants and personal injury plaintiff attorneys try to inappropriately strip them of even reasonable fees for their work.

Last week, in Joiner v. IWCC (Ceco Concrete Construction), No. 1-16-1866WC, issued 09/29/2017, Claimant Joiner filed a workers’ compensation claim in November 2008, with the assistance of attorney Neal Wishnick of Sostrin & Sostrin. After around two years of work by the Claimant attorney, in June 2010, Joiner discharged Wishnick and hired Andrew Leonard of the Leonard Law Group.

One week later, Wishnick and the Sostrin law firm filed a petition to protect their fees and costs—in such settings, adjudication of fees awaits the resolution of the claim via settlement or hearing/appeals.

Around four years later, in September 2014, Joiner again switched attorneys, discharging Attorney Leonard and hiring Fran Fishel of Brill & Fishel. Similar to the Wishnick/Sostrin fee/cost petition, Attorney Leonard filed their own petition for fees/costs.

In the middle of the next year, in July 2015, Ceco Construction offered Claimant $290,000 to settle the WC case. After Fishel conveyed the offer to Joiner, Claimant summarily fired Fishel. That same day, Fishel filed her petition for attorney fees with the Arbitrator.

Meanwhile, Joiner filed a civil action in the Circuit Court of Cook County, seeking damages for the injuries he sustained in the same work-related accident. Counsel for Joiner named his employer as a party defendant in the civil action.

Nine days after Joiner fired Fishel, he entered into a settlement agreement with his employer. The terms of the agreement provided that Joiner was accepting gross payment of $750,000 with $430,000 to be paid by a third-party defendant and $320,000 to be paid by his employer in exchange for a dismissal of his civil action. At that time, the IWCC computer indicates a fourth advocate who was a PI specialist represented Claimant.

The agreement outlined $1 settlement contracts for resolution of Joiner’s comp claim. Claimant Joiner and his counsel also agreed to hold his employer harmless for any claims brought by his various former attorneys in exchange for a waiver of the employer’s comp lien.

After Joiner agreed to the settlement, Claimant’s attorney advised his prior attorneys of a hearing for Arbitrator’s approval of the deal. In the letter, Counsel for Plaintiff appears to have offered  "20% of $1” or .20 cents under the terms of the IWCC fee agreement with Claimant. At the same time, current counsel for Joiner offered to pay Fishel $10,000 for her services, as a "professional courtesy,” if Fishel did not object to the WC or PI settlement.  Fishel declined the offer.

At the hearing, Arbitrator Kane determined attorney’s fees due each of Joiner’s comp attorneys would be calculated using the employer’s $320,000 contribution to the settlement. He further ruled since Claimant entered into agreements with each of his comp attorneys providing for a 20% fee, the Arbitrator ruled the three attorneys were collectively entitled to $64,000, representing 20% of the employer’s $320,000 contribution. Arbitrator divided that value into thirds and ordered Claimant and counsel to pay Sostrin, Leonard, and Fishel $21,333.33 each within 30 days of receipt of the settlement proceeds.

Joiner then fired Attorney Number Four! He then hired a new workers' compensation attorney and they filed a Petition for Review of Arbitrator Kane's decision as to the fees owed to his three prior attorneys.

On review, the Illinois Workers’ Compensation Commission ordered the terms of the $1 settlement contract be amended to indicate the workers’ compensation claim was settled for $320,000, and the panel ordered Claimant and counsel pay Sostrin, Leonard and Fishel $21,333.33 each, for a total of $64,000 in fees.

Claimant and counsel then appealed the IWCC ruling to the Circuit Court of Cook County, without filing an appeal bond. The three prior WC firms, Wishnick/Sostrin, Leonard and Fishel filed a motion to dismiss Joiner’s complaint, arguing his failure to post the requisite appeal bond deprived the Circuit Court of jurisdiction to review the Commission's order. The Circuit Court judge agreed and granted the motion to dismiss.

Claimant then filed another appeal! The Illinois Appellate Court, WC Division said Section 19(f)(2) of the Workers’ Compensation Act provides no summons authorizing a Circuit Court to review a decision issued by the Commission can be issued “unless the one against whom the commission shall have rendered an award for the payment of money shall, upon the filing of his written request for such summons, file with the clerk of the court a bond conditioned that if he shall not successfully prosecute the review, he will pay the award and the costs of the proceedings in the courts.”

The Appellate Court, WC Division said Illinois case law established strict compliance with obtaining a statutory appeal bond is required to vest subject-matter jurisdiction in the Circuit Court (and reviewing courts thereafter). If the bond is not obtained from an appropriate bonding company, the Appellate Court said, the Circuit Court had no jurisdiction to review a Commission decision. The Appellate Court, WC Division added the language Section 19(f)(2) makes it clear the appeal bond requirement applies to anyone the Commission has found liable for the payment of money, not just employers. “No rule of statutory construction authorizes us to declare that the Legislature did not mean what the plain language of the statute imports, nor may we rewrite a statute to add provisions or limitations the Legislature did not include,” the Appellate Court, WC Division said.

The Appellate Court also said it was not persuaded by Claimant’s argument the Commission lacked jurisdiction to award $64,000 in fees to his prior attorneys when he supposedly settled his workers’ compensation claim for $1. The Appellate Court, WC Division said the Circuit Court could not have considered this argument, since the Circuit Court lacked jurisdiction to consider this case. The Court’s members also agreed they could not decide the issue either but suggested the Commission’s award was appropriate, since the Commission has statutory authority to fix the amount of any fee payable to an attorney in a workers’ compensation case.

To read the decision, click here. We appreciate your thoughts and comments. Please post them on our award-winning blog.

Synopsis: IL Work Comp Commission Heralds Shiny New Website and E-Filing is Coming to a Computer Near You Soon.

Editor’s comment: The Illinois Workers’ Compensation Commission has unveiled their new website as the first phase of their effort to modernize and completely discontinue the use of paper documents with an online “portal” for filing e-claims and judicial documents.

The nice new website replaced the old home page that forced IL WC system participants to use a search engine to navigate. The new home page has six prominent buttons to direct the public and system users to needed information.

Titled the Digital Transformation Project, the next phase is an electronic filing system currently being designed by WorkComp Strategies in a two-year, $807,000 program, said the firm’s founder, Matthew Bryant. “We’ve been meeting with stakeholders such as insurance companies, the Illinois Chamber of Commerce, attorneys and arbitrators to find out their e-filing requirements. Phased implementation will be starting in January. Small portions will come online in the course of the next year,” Bryant said. “Our goal is to have most of the e-filing capabilities completed by the end of the next calendar year,” he said.

First up will be the e-filing of judiciary documents, including the submission and approval of draft settlement contracts. Those forms have always been called “pinks,” he said, because they were created and required to be delivered for approval by the IL WC Commission on pink paper. The colored paper thing was probably an analog effort to streamline technology from way back in the 50’s or 60’s. Most of the good ole “Industrial Commission” forms were on different colored paper.

“E-filing of pinks is a big deal in Illinois,” Bryant said. “That will be an online process. We’ll then do the rest of the judiciary stuff. Then first reports of injury and subsequent reports of injury will go online around the beginning of 2019. We’re also going to e-file self-insurance applications and claims for the Rate Adjustment Fund.”

The Rate Adjustment Fund was created in 1975 to pay cost-of-living increases to permanently and totally disabled workers or survivors of workers killed on the job. RAF payments are funded by payers and end when eligibility for PTD or survivor’s benefits cease. I am not shy to tell my readers I abhor the RAF and consider it one fashion in which Illinois hugely over-compensates some injured workers. Happy to explain to anyone that is interested.

Illinois currently allows the submission of only first reports of injury electronically through Release 1.0 by the International Association of Industrial Accident Boards and Commissions, but will move that process to the new e-system next year.

WorkComp Strategies is helping IWCC regulators get ready for procurement early next year of software vendors to take on small-scale projects that will contribute to overall web portal development and system integration, Bryant said.

Gov. Bruce Rauner created DoIT by executive order on Jan. 25, 2016, to modernize the information technology functions of every executive branch agency. Illinois has merged 38 IT silos under one roof — DoIT.

“It is past time for the Commission to update to today’s technology,” IWCC Chairwoman Joann Fratianni said in a press release a year ago. “Instead of having rooms and warehouses filled with millions of paper files, our new online record-keeping will help us significantly improve customer service, save costs and make the entire workers’ comp process more efficient.”

When completed by late 2021, the Commission’s new e-filing system will replace systems that are four decades old.

All of the money for the Digital Transformation Project comes from a settlement fund created when the state agreed to resolve a lawsuit filed by the Illinois Chamber of Commerce over new business fees imposed by Gov. Rod Blagojevich, who remains imprisoned for unrelated corruption. Blagojevich increased the fees to plug a $5 billion shortfall in the budget.

Once implemented, DoIT will maintain the Commission’s e-filing system, which regulators say will come with many benefits: easy online filing of claims and forms, standardized electronic data interchange submissions, reduced paper processing and storage, decreased mailing costs, and the ability to analyze data and metrics.

While I hate to be the bearer of bad news, once all these new automations are in place, we have to hope this Agency will start to someday streamline their work force and save IL businesses and small governments money. Yes, it might happen.

We appreciate your thoughts and comments. Please post them on our award-winning blog.

10-2-2017; IL WC "Video Replay" Reversed; Claimants and Claimant Attorneys--Exercise Caution Riding on Zombie Dragons and more

Synopsis: Work Comp “Video Replay” Reversed!!! Another WC Claim Gets Clawed Through IL WC’s “Corrected Decision” Grinder.

 

Editor’s comment: The purpose of Section 19(f) of the IL WC Act is to basically allow the equivalent of the NFL or Major League Baseball’s video replay in relation to decisions of the IL WC Arbitrators or Commission panels. If they obviously mess something up via improper calculation or other mistake, either party can file a “Petition to Correct Clerical Error” to have a decision recalled and corrected, similar to correction of a call of an umpire or referee. Similar to instant replay review, the IWCC version is limited to technical/mathematical but not substantive errors.

 

What I call the “Corrected Decision” Grinder is this “replay concept” effectively cancels the first ruling, as if It never happened. In my view, the IWCC procedure is mildly confusing and someone, someday might want to make it simpler for everyone in the system to understand and/or implement. If you file a 19(f) Petition, you can’t motion it for hearing--the matter sits for an undetermined period until someone from the IWCC considers it. At some random and unstated time that might be a day or a week or months and months, someone at the IWCC will issue either a

 

·         Denial of the Petition to Correct or

·         Order recalling the decision with the mistake in it.

 

If they issue a denial of a Petition to Correct an Arbitrator’s ruling, you have 30 days to file an appeal to the IWCC. In this instance, you are appealing the initial decision of the Arbitrator.

 

If they issue an order recalling the decision of an Arbitrator’s ruling, you are supposed to physically return the original decision of the Arbitrator, basically making it disappear—POOF! Then you need to wait an undetermined amount of time for the new and corrected decision to be filed/served on you. At that time, if you remain unhappy with the ruling, you must appeal the corrected ruling and ignore the first ruling.

 

In Eddards v. IWCC, No. 3-15-0757WC, issued 09/28/2017, Claimant filed an IL WC claim, asserting she injured her shoulder working for a nursing home. Four years ago, in September 2013, Arbitrator Dollison found Claimant suffered a compensable injury. The Arbitrator awarded Claimant six weeks of temporary total disability benefits and 12.65% BAW for permanent partial disability benefits, along with $34,177.75 for medical expenses.

 

The employer filed a motion to recall the Arbitrator’s decision to correct a clerical error. The Arbitrator recalled the initial decision and issued a corrected decision in October 2013, and the employer filed a petition for review of the Arbitrator’s decision in November 2013. It appears someone put the date of the first or recalled decision on the Petition for Review—OOPS!

 

The Illinois Workers’ Compensation Commission reversed the Arbitrator, finding Claimant had not suffered a compensable work-related injury. After the Circuit Court of La Salle County confirmed the Commission’s decision, Claimant sought review by the Appellate Court, WC Division.

 

The Appellate Court, WC Division reversed the denial and reinstated the Arbitrator’s award. Their ruling explained an IL WC arbitrator’s decision becomes final unless a petition for review is filed within 30 days after the party’s receipt of the decision.

 

In this claim, the employer timely filed a petition for review within 30 days of receipt of Arbitrator Dollison’s corrected decision, but the Petition mistakenly requested review of the original decision, listing the date of the original but later vacated decision.

 

The Appellate ruling confirms the Arbitrator’s original decision was not final or appealable, since it was recalled and corrected, and because the employer never specifically requested review of the corrected decision, the Court ruled the corrected decision became final. The decision indicates Illinois WC law “requires strict compliance with the requirements for filing a petition for review of the arbitrator’s decision to the commission,” so the employer’s failure to seek review of the corrected decision within 30 days left the Commission without jurisdiction to review the finding of compensability.

 

The Court also asserted it could not treat the employer’s mistake as “a minor mistake or inadvertence when writing or when copying something on the record,” as the employer’s minor typographic mistake supposedly failed to provide Claimant or the Commission panel with requisite notice of which decision was being appealed. With respect to the members of our Appellate Court, I consider this statement/position to be something of a stretch—I am sure counsel for Claimant was fully on notice of what was being appealed and I am sure all issues were fully briefed and reviewed before the IWCC panel, prior to the panel making its ruling.

 

As the IL WC Commission lacked subject matter jurisdiction over the appeal, the Appellate Court, WC Division said the Circuit Court also lacked such jurisdiction, so neither the Commission decision nor the Circuit court decision could stand and both were vacated.

 

To read the decision, click here. We appreciate your thoughts and comments. Please post them on our award-winning blog.

 

 

Synopsis: When Riding a Zombie Dragon, Try Not to Get Eaten--IL Worker Hit With $100K “Balance Bill” Medical Bill Due to Failing to Respond to Suit.

 

Editor’s comment: As part of making a PI or WC claim, some Claimants and their attorneys encourage high medical bills to make “special damages” respectively high for settlements—I feel that strategy, like the zombie dragon from Game of Thrones, may come back to bite you. We assure our readers and I am sure you can tell if you read this decision, it is my opinion this medical/surgical provider is aggressive about billing and then uncompromising about collecting their bills.

 

We recently reviewed a ruling in which the Illinois Appellate Court ordered an injured worker to pay more than four times the IL WC Medical Fee Schedule value for surgical services because he failed to respond to a lawsuit from a medical provider while he pursued resolution of a third-party lawsuit. One Golden Rule to tell your kids, never ignore litigation against you.

 

If you review the decision in Illinois Neurospine Institute v. Carson, you will note how forceful and assertive IL WC medical billers can be. This unusual outcome started  began when a merchandiser for Coca-Cola, slipped and fell at a grocery store while at work on Dec. 21, 2010. It appears clear he herniated a disc as part of the slip/fall. He filed a workers' compensation claim on Feb. 1, 2011. He also started treating with Dr. Ronald Michael at the Illinois Neurospine Institute. Dr. Michael performed successful spine surgery on Claimant on March 24, 2012.

 

Claimant continued treating with Dr. Michael for more than a year until May 8, 2013, racking up a total medical/surgical/rehab bill of $124,743.71.

 

Shortly before Claimant's surgery and extensive post-surgical care, Illinois Neurospine Institute and Dr. Michael gave the patient a "financial responsibility statement." It filed the document on Feb. 9, 2012, with Claimant's name handwritten on the line labeled "Patient Name." The document required Claimant to  be sure Illinois Neurospine Institute was paid for its medical/surgical services. Illinois Neurospine Institute and Dr. Michael later used the document against their patient in court. Claimant asserted he never signed it.

 

On Feb. 27, 2014, Claimant settled his workers' compensation claim with Coca-Cola for $100,000. At the time of settlement of the WC claim, he paid the Illinois Neurospine Institute and Michael $27,003.59, in keeping with Illinois' Workers' Comp Medical Fee Schedule. Please note my opinion any further billing after a partial payment was accepted by a medical provider should have been statutorily prohibited “balance billing.” If you review the IL WC Act, it doesn’t provide any penalty for “balance billing,” it just prohibits such actions.

 

Almost two years later, Dr. Michael filed a breach of contract complaint on Jan. 13, 2016. Having been served with process, Claimant did not file an answer or seek any extension. Four months later, a default judgment was entered in the Institute and doctor's favor, confirming Claimant owed him the balance arguably outstanding or $98,276.78.

 

It appears Claimant was watching a third-party personal injury lawsuit; he sued the store where he slipped and fell in 2010. After that lawsuit wrapped up in October 2016, he moved to vacate the trial court's default judgment against him. Please note the judgment was now over 30 days old. The only relief from such a judgment is a Section 2-1401 Petition. When Claimant's attorney filed the response to the Section 2-1401 petition, it was missing an affidavit and language indicating Claimant swore the facts were true under the penalty of perjury. It did not claim Claimant acted with due diligence in answering the complaint or filing the response to the petition. Instead, it said, "A petition [for relief] may be granted even in absence of a showing of due diligence where justice or good conscience require."

 

Illinois Neurospine Institute filed a response asserting the petition should be denied on lack-of-due-diligence grounds. Claimant hadn't explained why he hadn't answered the initial complaint or why there was a delay in his filing of the Section 2-1401 petition, Illinois Neurospine Institute argued. Both factors showed a lack of due diligence, the Institute and Dr. Michael said.

 

Illinois Neurospine Institute’s attorney attached Dr. Michael's affidavit and a copy of the Financial Responsibility Statement to its response. A few weeks later, the trial court entered an order granting Claimant's petition to vacate the default judgment. Illinois Neurospine Institute and Dr. Michael appealed.

 

On review, the 1st District Appellate Court agreed with Illinois Neurospine Institute and Dr. Michael. It found Claimant had not shown due diligence, and the due diligence requirement is relaxed only "under extraordinary circumstances." No extraordinary circumstances appeared to be present here, the Court wrote.

 

We appreciate your thoughts and comments. Please post them on our award-winning blog.

 

Synopsis: Join KCBA at the IL Chamber of Commerce 2017 Workers' Compensation and Safety Conference! Wednesday, October 25, 2017 at the Hilton l 3003 Corporate Drive West l Lisle, IL 60532.  The program runs from 8:30 am – 3:30 pm.

 

Editor’s Comment: As part of the program, there are several Workshops which will include a presentation on Ethical Management of Disability & Employment Law Concerns Arising in Workers’ Comp Claims presented by our own John Campbell, Shawn Biery, & Brad Smith

 

The IL State Chamber also wants you to know:

 

This is the most important annual Workers’ Compensation Conference for Illinois employers!

·        The 10th Annual Workers’ Compensation and Safety Conference will include valuableinformation for all Illinois Employers with all new topics and fresh presenters.  

 

Workers' Comp. Reform is being debated at the state Capitol.

·        Get the latest analysis and thoughts on WC reform at the conference, along with cost-controlling measures, safety issues to prevent workers’ injuries, and discussion of court cases as well as much more.

 

Continuing Education Available!

·        This conference has been pre-approved to offer 3 HRCI credits.

·        This conference has been pre-approved to offer 4 SHRM Professional Development credits.

·        This conference has been submitted for approval to offer 4 CLE credits for attorneys.

 

- Learn More -

 

 

You may also contact Shawn Biery at 312-756-3701 or sbiery@keefe-law.com or the Chamber directly via Laurie Silvey at (217) 522-5512 ext 223 or lsilvey@ilchamber.org