Appeal of JoAnn Hoff

CourtSupreme Court of New Hampshire
DecidedFebruary 24, 2021
Docket2019-0622
StatusUnpublished

This text of Appeal of JoAnn Hoff (Appeal of JoAnn Hoff) is published on Counsel Stack Legal Research, covering Supreme Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Appeal of JoAnn Hoff, (N.H. 2021).

Opinion

THE STATE OF NEW HAMPSHIRE

SUPREME COURT

In Case No. 2019-0622, Appeal of JoAnn Hoff, the court on February 24, 2021, issued the following order:

Having considered the briefs and oral arguments of the parties, the court concludes that a formal written opinion is unnecessary in this case. The claimant, JoAnn Hoff, appeals an order of the Compensation Appeals Board (CAB) reducing her temporary disability compensation benefits to a fixed rate. She primarily argues that the CAB erred by concluding that a change in conditions occurred justifying the reduction in benefits. See RSA 281-A:48 (Supp. 2020). We affirm.

The following facts were found by the CAB or are supported by the record. On October 23, 2017, the claimant was injured while working as a licensed practical nurse for Valley Regional Hospital, Inc., the employer. She thereafter reported experiencing lower back pain and numbness in her legs. An MRI revealed a lumbar disc protrusion. The claimant began receiving temporary disability benefits in November 2017. See RSA 281-A:28 (2010). On December 14, 2017, Dr. Pikus performed surgery on the claimant to address her leg symptoms. During follow-up appointments in early 2018, Dr. Pikus consistently noted that the claimant’s leg symptoms had resolved, but her back pain persisted. At a physical therapy appointment in May 2018 the claimant stated: “I think I could go back to work and do desk work.”

In June 2018, the claimant returned to Dr. Pikus, reporting that her leg symptoms had returned. He ordered another MRI, which showed no significant negative changes compared with the previous one. Although the claimant continued to report back pain, Dr. Pikus noted that the cause of her pain was uncertain. Accordingly, he referred her to Dr. Mason for a physiatric evaluation and assistance with returning to work.

The claimant also underwent an independent medical evaluation in June 2018, at the request of the respondent, the employer’s workers’ compensation insurance carrier. See RSA 281-A:38 (Supp. 2020). Dr. Rudolf, who performed the IME, reviewed the claimant’s medical records relating to her injury, interviewed the claimant, and performed a physical examination. He noted that the claimant reported ongoing back pain and numbness in her left foot and leg. He also observed that she experienced back discomfort when standing for short periods of time and walking for a distance longer than thirty feet, and that she could not lift more than seven to ten pounds or easily climb or descend stairs. The IME report notes the claimant’s statements that she could sit for extended periods of time if she adjusted positions and that she sat comfortably during the interview portion of the IME without displaying any “obvious pain behavior.” Based upon his evaluation, Dr. Rudolf concluded that the claimant had “a work capability doing a sit down occupation,” primarily desk work, and that she should “avoid long periods of standing or walking, no lifting or carrying greater than [ten] pounds.”

As a result of the IME, on July 11, 2018, the employer offered the claimant a temporary, full-time position, as a patient access representative, which would involve completing “a variety of secretarial tasks.” See RSA 281- A:23-b (2010). A workers’ compensation task analysis, which was completed by the employer to evaluate the physical requirements of the temporary position, described the position as requiring occasional — between 1% and 33% of the time — standing and walking, and continuous — between 67% and 100% of the time — sitting, reaching, and fine motor skills. The claimant testified at a subsequent Department of Labor (DOL) hearing that she neither returned to work after receiving the offer, nor communicated with her employer about the offer.

On August 8, Dr. Mason saw the claimant and opined that she could not return to full duty work or her “regular job” as a licensed practical nurse. At the DOL hearing, the claimant testified that she did not inform Dr. Mason of the temporary position that she had been offered.

In September 2018, the respondent sent Drs. Pikus and Mason letters with the employer’s temporary job offer and workers’ compensation task analysis attached, requesting their opinion regarding whether the claimant was capable of performing the job. Dr. Pikus opined that she could perform the job, with a “sit/stand modification.” Dr. Mason opined that the claimant was capable of performing the job, and noted: “please allow occasional break to stand/stretch/reposition.”

In October 2018, the claimant sought and obtained appointments to be seen separately by both Drs. Pikus and Mason, complaining of back pain. On December 9, 2018, the claimant completed a functional capacity evaluation (FCE) to determine her work ability. The report found that the claimant could not maintain static standing without the support of one hand for more than one minute, could maintain static standing with upper extremity support for eight minutes, could tolerate dynamic standing for twenty-five consecutive minutes, and was able to walk 400 feet with the assistance of a cane. The FCE also found that she could sit for over an hour at once, and for twenty-minute intervals thereafter. Based upon the claimant’s performance, the FCE report concluded that she could not “return to office type nursing like she was doing prior to [the] injury.” The report further concluded that the claimant “can tolerate full[-]time employment at a sedentary physical demand level,” with

2 “dynamic standing limited to [twenty-five] minutes at most occasionally in the course of a work day” and walking “limited to 400[] [feet] at most at a time.”

The respondent requested a DOL hearing to review the claimant’s benefits eligibility. See RSA 281-A:48. On January 31, 2019, a DOL hearing officer held a hearing and thereafter concluded that the claimant was capable of full-time sedentary work and, thus, that a change in conditions occurred justifying a reduction in benefits. See id. The hearing officer reduced the claimant’s benefits to a fixed partial rate. Following the DOL hearing, on February 20, 2019, Dr. Mason saw the claimant and determined that she could not return to work, but “was made aware of [the] FCE,” and, in the record for that visit, wrote: “Please refer to this detailed assessment [regarding] work abilities.”

The claimant appealed the DOL hearing officer’s decision to the CAB, which conducted a de novo hearing. The CAB concluded that the claimant had work capacity based upon the FCE, IME, Dr. Pikus’s approval of the job offer, and Dr. Mason’s deferral to the FCE regarding work capacity. The CAB therefore granted the respondent’s request to reduce the claimant’s compensation to a fixed rate. The claimant filed a motion for reconsideration and rehearing, in which she argued, in part, that any job offer she received from the employer was not approved by her treating physicians, as required by the relevant regulation. See N.H. Admin. R., Lab 504.04(g). The CAB denied her motion, and this appeal followed.

We will not set aside or vacate the CAB’s decision except for errors of law, unless the court is satisfied, by a clear preponderance of the evidence before it, that the decision is unjust or unreasonable. Appeal of CNA Ins. Cos., 143 N.H. 270, 272 (1998); see RSA 541:13 (2007). Our review of the CAB’s factual findings is deferential. Appeal of Hartford Ins. Co., 162 N.H. 91, 93 (2011); see RSA 541:13 (“[A]ll findings of the [CAB] upon all questions of fact properly before it shall be deemed to be prima facie lawful and reasonable.”).

The claimant argues that the CAB erred by concluding that a change in conditions occurred under RSA 281-A:48, justifying a reduction in benefits. We disagree.

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Appeal of JoAnn Hoff, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-joann-hoff-nh-2021.