Workers’ Comp In-Cites
Welcome to the latest edition of Schaff & Young's Workers' Comp In-Cites. Designed to provide our clients with practical insight, Workers' Comp In-Cites outlines recent developments in Pennsylvania workers' compensation law and explains how those decisions impact our clients and their cases. Barbara Young, Michael Schaff and the other attorneys at Schaff & Young, P.C. are always available to discuss these cases – or any other questions or concerns you might have. Just give us a call at (215) 988-0090 or send an email to We look forward to hearing from you.

Judges Must Evaluate Abnormal Working Conditions on a Case-by-Case Basis

In order to determine whether a purely psychiatric injury is compensable, a Workers’ Compensation Judge must consider whether the underlying events represented a singular, extraordinary event or was a normal working condition, according to the Commonwealth Court in Murphy v. Workers’ Compensation Appeal Board (Ace Check Cashing, Inc.). In this case, the Court remanded the matter for the WCJ to consider whether an armed robbery in a check cashing agency met the standard set forth by the Supreme Court in Payes v. Workers’ Compensation Appeal Board (PA State Police).

March 2015 Edition
Volume IX
Number 3

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Judges May Not Create Their Own Criteria When Evaluating the Competency of IRE Physicians

So ruled the Commonwealth Court in IA Construction Corp. v. Workers’ Compensation Appeal Board (Rhodes). In this case, the Court held that the determination whether a physician is qualified to perform an Impairment Rating Evaluation is governed by the Section 306(a.2)(1) of the Act. Thus, a WCJ may not impose greater qualifications upon a physician performing an IRE than those set forth in the Act.

No Partial Disability Benefits If Loss of Earnings Is Related Solely to Economic Conditions

In Donahay v. Workers’ Compensation Appeal Board (Skills of Central PA, Inc.), the Commonwealth Court held that when a claimant’s loss of earnings is attributable to economic conditions, rather than the work-related injury, the claimant is not entitled to partial disability benefits.