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Workers' Compensation

Wyoming: Claimant Deemed at MMI Despite Continued Use of Spinal Cord Stimulator to Reduce Pain

The Supreme Court of Wyoming affirmed a finding by the state’s Office of Administrative Hearings (OAH) that a workers’ compensation claimant had reached MMI—with a resulting end to TTD benefits—despite a medical treatment plan, on the part of the claimant’s medical providers, to use a spinal cord stimulator to reduce the claimant’s pain and improve his quality of living. The high court noted that the OAH properly applied the legal principles regarding TTD, MMI, ascertainable loss, and permanent partial impairment under Wyo. Stat. Ann. § 27-14-405 (2017), which focused on the underlying condition, rather than pain. 

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance. 

See Coggins v. State ex rel. Department of Workforce Servs., 2018 WY 77, 2018 Wyo. LEXIS 82 (July 10, 2018)

See generally Larson’s Workers’ Compensation Law, § 80.03.

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law