Megan Vaniman

Brown v. SAIF: End of the Combined Condition?

Vaniman-Megan_160-x-222A recent Court of Appeals decision changes the test for closing an accepted combined condition claim. What does Brown v. SAIF mean for employers and insurers? In Brown v. SAIF, SAIF initially accepted a lumbar strain and was later ordered to accept a lumbar strain combined with lumbar disc disease and spondylolisthesis. A closing exam demonstrated the accepted condition was no longer the major contributing cause of the need for treatment or disability of the combined condition. SAIF then issued a current combined condition denial which claimant appealed. The ALJ and Board upheld the denial. The Court of Appeals reversed finding the proper inquiry was whether the compensable injury, not the accepted condition, was no longer… Continue reading