Texas Department of Insurance, Division of Workers' Compensation// Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust v. Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust// Cross-Appellee, Texas Department of Insurance, Division of Workers' Compensation

CourtCourt of Appeals of Texas
DecidedFebruary 28, 2023
Docket03-21-00074-CV
StatusPublished

This text of Texas Department of Insurance, Division of Workers' Compensation// Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust v. Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust// Cross-Appellee, Texas Department of Insurance, Division of Workers' Compensation (Texas Department of Insurance, Division of Workers' Compensation// Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust v. Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust// Cross-Appellee, Texas Department of Insurance, Division of Workers' Compensation) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Texas Department of Insurance, Division of Workers' Compensation// Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust v. Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust// Cross-Appellee, Texas Department of Insurance, Division of Workers' Compensation, (Tex. Ct. App. 2023).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-21-00074-CV

Appellant, Texas Department of Insurance, Division of Workers’ Compensation// Cross- Appellants, Accident Fund Insurance Company of America and Texas Cotton Ginners’ Trust

v.

Appellees, Accident Fund Insurance Company of America and Texas Cotton Ginners’ Trust// Cross-Appellee, Texas Department of Insurance, Division of Workers’ Compensation

FROM THE 53RD DISTRICT COURT OF TRAVIS COUNTY NO. D-1-GN-18-000341, THE HONORABLE MAYA GUERRA GAMBLE, JUDGE PRESIDING

MEMORANDUM OPINION

This declaratory-judgment action was brought pursuant to Section 2001.038 of the

Texas Government Code. Appellees and cross-appellants, Accident Fund Insurance Company of

America and Texas Cotton Ginners’ Trust, are two insurance carriers that successfully challenged

the validity and applicability of an agency rule regarding eligibility for workers’ compensation

supplemental income benefits (SIB), 28 Texas Administrative Code Section 130.102 (the Rule),

which adopted rules pursuant to Texas Labor Code Section 408.142 (the Statute). 28 Tex. Admin.

Code §130.102 (2009) (Tex. Dep’t of Ins., Div. of Workers’ Comp., Eligibility for Supplemental

Income Benefits; Amount). 1 The appellant and cross-appellee, the Department of Insurance,

1 All citations to agency rules are to the current version. Division of Workers’ Compensation (the Division) is the state agency designated to oversee the

workers’ compensation system and that promulgated the challenged rule. Tex. Lab. Code

§ 402.001. The Division appeals the district court’s rulings that Section (d)(1)(D) of the Rule was

invalid and that Section (f)’s mention of “work search contacts” is inapplicable to individuals who

complete work searches on their own without the involvement of the Texas Workforce

Commission (TWC). In their cross-appeal, the carriers challenge various agency materials of the

Division as invalid ad hoc rules, which the district court ruled were not ad hoc rules. 2 Accident

Fund Insurance Company also challenges on cross-appeal, the district court granting the Division’s

motion to exclude Accident Fund’s expert witness. We will reverse in part and affirm in part the

district court’s order.

BACKGROUND

The Workers’ Compensation Act was enacted “to balance the competing interests

of providing ‘compensation for injured employees while protecting employers from the costs of

litigation.’” SeaBright Ins. v. Lopez, 465 S.W.3d 637, 642 (Tex. 2015). The system offers “four

levels of income benefits: 1) temporary income benefits; 2) impairment income benefits;

3) supplemental income benefits; and 4) lifetime benefits.” Texas Workers’ Comp. Comm’n

v. Garcia, 893 S.W.2d 504, 513 (Tex. 1995). At issue here, are the SIB. SIB are longer term

disability compensation that apply after temporary and impairment benefits have ceased, and the

injured employee has a remaining impairment rating of 15 percent or more and is unemployed or

2 The Division argues that the carriers’ ad hoc rules challenge and excluded-witness challenge are improperly before this Court because a party who does not file a notice of appeal may not be granted more favorable relief than did the trial court except for just cause. See Tex. R. App. P. 25.1. However, because the carriers filed timely notices of appeal, we reach the merits of their cross-appeal issues. 2 underemployed. See Tex. Lab. Code § 408.142; Garcia, 893 S.W.2d at 513 (Tex. 1995). To be

eligible for quarterly SIB payments, an injured worker who meets all other requirements, must

“demonstrate an active effort to obtain employment,” by either participating in a vocational

rehabilitation program or completing the required “work search efforts” for the qualifying period.

Id. §408.142(a); 28 Tex. Admin. Code §130.102(d) (Eligibility for Supplemental Income Benefits;

Amount).

Relevant here are the statutory requirements for satisfactory “work search efforts” to

receive SIB payments. Specifically, the parties dispute what the Statute requires of an injured

employee that is searching for work on their own—compared to through a vocational rehabilitation

program or through the TWC—to be entitled to SIB payments. The carriers are insurance

companies who provide coverage of SIB for employers of injured workers. The Division

promulgated the challenged rule. See 28 Tex. Admin. Code § 130.102(d), (f) (Eligibility for

Supplemental Income Benefits; Amount).

The Statute was amended during the 2005 legislative session, and the Section

relevant here currently reads:

(a) The commissioner by rule shall adopt compliance standards for supplemental income benefit recipients that require each recipient to demonstrate an active effort to obtain employment. To be eligible to receive supplemental income benefits under this chapter, a recipient must provide evidence satisfactory to the division of:

(1) active participation in a vocational rehabilitation program conducted by the Department of Assistive and Rehabilitative Services or a private vocational rehabilitation provider;

(2) active participation in work search efforts conducted through the Texas Workforce Commission; or

3 (3) active work search efforts documented by job applications submitted by the recipient.

(b) In adopting rules under this section, the commissioner shall:

(1) establish the level of activity that a recipient should have with the Texas Workforce Commission and the Department of Assistive and Rehabilitative Services;

(2) define the number of job applications required to be submitted by a recipient to satisfy the work search requirements; and

(3) consider factors affecting the availability of employment, including recognition of access to employment in rural areas, economic conditions, and other appropriate employment availability factors.

(c) The commissioner may consult with the Texas Workforce Commission, the Department of Assistive and Rehabilitative Services, and other appropriate entities in adopting rules under this section.

Tex. Lab. Code §408.1415.

In 2009 the Division amended the Rule, adding the new work-search-efforts standard

to the SIB-eligibility rules:

(d) Work Search Requirements.

(1) An injured employee demonstrates an active effort to obtain employment by meeting at least one or any combination of the following work search requirements each week during the entire qualifying period:

(A) has returned to work in a position which is commensurate with the injured employee’s ability to work;

4 (B) has actively participated in a vocational rehabilitation program as defined in § 130.101 of this title (relating to Definitions);

(C) has actively participated in work search efforts conducted through the Texas Workforce Commission (TWC);

(D) has performed active work search efforts documented by job applications; or

(E) has been unable to perform any type of work in any capacity, has provided a narrative report from a doctor which specifically explains how the injury causes a total inability to work, and no other records show that the injured employee is able to return to work.

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Texas Department of Insurance, Division of Workers' Compensation// Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust v. Accident Fund Insurance Company of America and Texas Cotton Ginners' Trust// Cross-Appellee, Texas Department of Insurance, Division of Workers' Compensation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-department-of-insurance-division-of-workers-compensation-accident-texapp-2023.