Workers’ Compensation
Ca. Workers' Comp. Quarterly 2019, Vol. 32, No. 2
Content
- 2019 Steve Jimenez Memorial Special Recognition Awards
- Approaches to Care for Catastrophic Cases
- "Impermissible Factors" in Apportionment: a History of the Current Legal and Legislative Debate
- Note from the Editor
- Why the Carve-Out Works When the Comp System Does Not
- Wilson En Banc Decision Takeaways
- Workers' Compensation Section 2018-2019 Executive Committee Roster
- Adding Versus Combining Ratings: An Update on the Kite Line of Cases and Rebuttal of the Combined Values Chart
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.