A Guide to Properly Adding Impairments

DANE P. GILLIAM, ESQ.

NEWPORT BEACH, CALIFORNIA

INTRODUCTION

Nearly eleven years ago, the landmark case of Athens Administrators v. WCAB (Kite) (2013) 78 CCC 213, provided a basis for a doctor to rebut the Combined Values Chart ("CVC") and add whole person impairments instead of combining them. In the decade plus since Kite was issued, there has been much litigation and confusion over how to properly apply the additive method, who can add the impairments, what impairments can be added, what type of analysis is needed to perfect the additive method, and what buzzwords should be used by the doctors to support their findings.