Workers’ Compensation

Ca. Workers' Comp. Quarterly 2019, Vol. 32, No. 2

Adding Versus Combining Ratings: An Update on the Kite Line of Cases and Rebuttal of the Combined Values Chart

Kenneth Kingdon, Esq.

San Pedro, California

One of the hottest areas of litigation in the last several years has been whether the applicant’s multiple permanent disabilities should be combined using the Combined Values Chart (CVC) or simply added. The answer to that question can have a dramatic impact on the applicant’s overall recovery and the employer’s liability. This article updates the practitioner on the current status of the law and parameters the WCAB is setting.


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