BILL ANALYSIS                                                                                                                                                                                                    Ó





          SENATE COMMITTEE ON LABOR AND INDUSTRIAL RELATIONS
                             Senator Tony Mendoza, Chair
                                2015 - 2016  Regular 

          Bill No:               AB 305       Hearing Date:     June 24,  
          2015
           ----------------------------------------------------------------- 
          |Author:    |Gonzalez                                             |
          |-----------+-----------------------------------------------------|
          |Version:   |June 15, 2015                                        |
           ----------------------------------------------------------------- 
           ----------------------------------------------------------------- 
          |Urgency:   |No                     |Fiscal:    |No               |
           ----------------------------------------------------------------- 
           ----------------------------------------------------------------- 
          |Consultant:|Gideon Baum                                          |
          |           |                                                     |
           ----------------------------------------------------------------- 
          
                Subject:  Workers' compensation: permanent disability  
                                   apportionment.


          KEY ISSUE
          
          Should the Legislature prohibit apportionment if pregnancy,  
          menopause, or menopause-caused osteoporosis is contemporaneous  
          with the injured worker's claimed injury?

          Should the Legislature require that breast cancer not be less  
          than the comparable impairment rating for prostate cancer,  
          despite the fact that breast cancer does not generally create a  
          comparable level of impairment?

          ANALYSIS
          
           Existing law  establishes a workers' compensation system that  
          provides benefits to an employee who suffers from an injury or  
          illness that arises out of and in the course of employment,  
          irrespective of fault.  This system requires all employers to  
          secure payment of benefits by either securing the consent of the  
          Department of Industrial Relations to self-insure or by securing  
          insurance against liability from an insurance company duly  
          authorized by the state.









          AB 305 (Gonzalez)                                       Page 2  
          of ?
          
           Existing law  requires that, if an occupational injury results in  
          a permanent disability, the percentage of disability to total  
          disability shall be determined, and the disability payment  
          computed on the basis of the percentage of disability to total  
          disability. (Labor Code §4658)

           Existing law  requires that, when doctors are determining the  
          nature and severity of an occupational injury, the American  
          Medical Association (AMA) Guides to the Evaluation of Permanent  
          Impairment (5th Edition) must be used to measure physical  
          impairment and determine an injured worker's whole person  
          impairment (WPI). (Labor Code §4660.1)
           
          Existing law  creates the Permanent Disability Ratings Schedule  
          (PDRS), which increases the WPI by 40% and adjusts for  
          occupation and age to calculate a percentage of permanent  
          disability (PD), also known as a PD rating. (Labor Code §4660.1)

           Existing law  requires that any physician who prepares a report  
          addressing the issue of permanent disability include an  
           apportionment determination  , where the physician determines what  
          approximate percentage of the permanent disability  was caused by  
          other factors,  including prior industrial injuries. (Labor Code  
          §4663)
           
          This bill  would require that WPI ratings for breast cancer and  
          its sequelae shall in no event be less than comparable WPI  
          ratings for prostate cancer and its sequelae.

           This bill  would prohibit apportionment in cases of physical  
          injury based on any of the following conditions if those  
          conditions  are contemporaneous  with the claimed physical injury:

             1)   Pregnancy;
             2)   Menopause; and
             3)   Osteoporosis casually related to menopause.

           This bill  would also prohibit apportionment in cases of  
          psychiatric injury caused by sexual harassment or any of the  
          conditions listed above if the conditions are contemporaneous  
          with the psychiatric injury.

           This bill  would also remove the requirement that a physician  
          include an apportionment determination in a permanent disability  
          report.







          AB 305 (Gonzalez)                                       Page 3  
          of ?
          


          COMMENTS
          
          1.  A Brief Word on the AMA Guides:

            The AMA Guides were first published in 1971 to provide "a  
            standardized, objective approach to evaluating medical  
            impairments". The Guides define "impairment" as a loss, loss  
            of use, or derangement of any body part, organ system, or  
            organ function. Excluding the introductory chapters, each  
            chapter of the AMA Guides deals with a specific area of the  
            body or a specific type of permanent impairment and discusses  
            how to measure impairment in a specific individual. This  
            impairment measurement is a percentage known as the whole  
            person impairment (WPI), with a higher WPI percentage  
            signifying a higher level of impairment.

            WPI serves as the foundational calculation for the purposes of  
            calculating a Permanent Disability (PD) rating. In bringing  
            the AMA Guides into the workers' compensation system in 2004,  
            the goal was to make the measurement of impairment, and by  
            extension PD ratings, more objective and uniform throughout  
            the state and based on the best available medical evidence.  
            Further, as a part of the 2012 reform, the Legislature  
            codified case law that allows doctors to "rate by analogy" or  
            to  use other chapters of the AMA Guides if those chapters  
            better explain the nature of the impairment  (see Milpitas  
            Unified School District v. Workers' Comp. Appeals Bd. (Guzman)  
            (2010) 187 Cal.App.4th 808).

            However, some proponents of the bill have argued that the AMA  
            Guides are not objective, specifically in the area of  
            gender-specific injuries. Specifically, proponents point to  
            the fact that the AMA Guides rate the removal of female  
            breasts at a WPI of 0%, while the removal of a prostate would  
            rate a 16%-20% WPI, arguing that such a rating shows bias  
            against women. This line of argument, however, has some  
            difficulties. 

            First,  the male prostate is not a strong equivalent to female  
            breasts  . The prostate is an exocrine gland that secretes  
            fluid, assisting the mobility of sperm after ejaculation. As  
            will be discussed in more detail below, removing the prostate  
            can lead to both incontinence and impotence. The closest  







          AB 305 (Gonzalez)                                       Page 4  
          of ?
          
            female equivalent, or homologue, to the prostate is the  
            skene's gland, which is located on the surface of the vulva.  
            Alternatively, one could also look at urthereal disease, which  
            would lead to incontinence.

            When we look at how the AMA Guides rate the female equivalent  
            injuries, we see comparable WPI ratings. For example, vulval  
            disease where sexual intercourse is not possible would be  
            26%-35% WPI. Additionally, urthereal disease which leads to  
            stress incontinence would be a 25% WPI at a minimum.  In short,  
            when looking at comparable injuries, both men and women appear  
            to receive comparable ratings through the AMA Guides.
             
            Second, as was noted above, a higher WPI indicates a higher  
            level of impairment, and the removal of a prostate is only  
            rated as a 16%-20% WPI if the prostate removal led to sexual  
            dysfunction or urinary incontinence. According to the American  
            Cancer Society, 25% to 75% of men who have their prostate  
            removed will be impotent, depending on the age and health of  
            the men. 

            The American Cancer Society does not note similar challenges  
            after recovering from a mastectomy, which is the surgical  
            removal of the mammary glands.   If a mastectomy resulted in  
            comparable impairment, a doctor would be able to provide a WPI  
            rating comparable to the removal of the prostate through SB  
            863 and Guzman.  The American Cancer Society does note that 20%  
            to 30% of women develop neuropathic pain near the site of the  
            surgery, though most women report that these symptoms are not  
            severe.  If they were severe pain, it is likely that they would  
            be ratable through the AMA Guides chapter on Pain  .

            As was noted above, AB 305 makes breast cancer sequelae (or  
            consequences of injury or disease) equally ratable as prostate  
            cancer sequelae. The likely consequence of this is that it  
            would require that mastectomies are rated the same as prostate  
            removal.  The Committee may wish to consider if a mastectomy  
            should be automatically rated as if it led to both sexual  
            dysfunction and incontinence, despite the fact it generally  
            does not.
           
          2.  A Brief Word on Apportionment: 

            Under existing law, every time a doctor prepares a report on  
            if a claimed workplace injury is permanently disabling, the  







          AB 305 (Gonzalez)                                       Page 5  
          of ?
          
            physician must determine causation AND what percentage of the  
            injury is due to non-occupational issues, including prior  
            workplace injuries. An injured worker's PD award is then  
            adjusted down by this percentage. Only a physician can  
            determine if apportionment is appropriate and to what degree.

            This makes apportionment a uniquely provocative policy. On one  
            hand, it would be difficult to defend requiring an employer to  
            provide PD awards for an injury that is unrelated to work or  
            occurred at another place of employment. This is why language  
            limiting PD awards to only cover the consequences of a  
            workplace injury has been in law since 1917. While the current  
            apportionment statute dates back to 2004, the idea behind it  
            is nearly a century old.

            On the other hand, determining what percentage of an injury is  
            or is not occupational is highly dependent on the judgment of  
            the physician. WCAB case law provides that an apportionment  
            finding is only valid if the physician's medical opinion:

             1)   Framed in terms of reasonable medical probability;
             2)   Not speculative;
             3)   Based on pertinent facts and on an adequate examination;  

             4)   Sets forth the reasoning in support of its conclusion;  
               and
             5)   Explains how and why the apportionable factor is  
               responsible for the disability.
            (See Escobedo v. Marshalls, (2005) 70 Cal. Comp. Cases 604)


            Despite this case law, sometimes physicians fail to meet these  
            requirements when making an apportionment determination.

            For example, in Rice v. City of Jackson, ADJ8701916 (2015), an  
            injured worker's PD award was apportioned by 49% due to  
            "family history", or the injured worker's father's history of  
            hip and back issues. The physician cited several journal  
            articles, but did not evaluate the injured worker's family or  
            connect the "how and why" such family history led to the  
            injured worker's level of permanent disability. The WCAB ruled  
            that apportioning on the basis of genetic predisposition was  
            inappropriate,  noted that apportioning on the basis of  
            immutable factors is impermissible  , and returned the case to  
            the local board for a new unapportioned award of permanent  







          AB 305 (Gonzalez)                                       Page 6  
          of ?
          
            disability. 
            
            Proponents have brought forward several examples of  
            apportionment that, like Rice, appear to fall into the arena  
            of physician failure. Each example is troubling. However, they  
            are a small sample; thousands of apportionment decisions are  
            issued each year and have been for over a decade. Staff notes  
            that it is currently unclear if such a small sample of  
            apportionment examples demonstrates systemic inequality  
            towards women or notable examples of physician error.  
          
            One final note on apportionment: the apportioning of a PD  
            award has no impact on the ability of an injured worker to  
            receive medical care. Even in the event that a PD award is  
            apportioned to 0%, the worker has a right to medical care if  
            the injury arises or occurs in the course of employment (See  
            Employers Mutual Liability Ins. Co. of Wisconsin v. Industrial  
            Acc. Com. (Gideon) (1953) 41 Cal.2d 676 and Reyes v. Hart  
            Plastering (2005) 70 Cal.Comp.Cases 223).

          3.  Several Implementation Challenges Facing AB 305 and  
            Apportionment:  

            AB 305 poses several unique questions on its full impact on  
            the workers' compensation system. 

            "Contemporaneous" and the WCAB

            As was noted above, apportionment of a PD rating cannot occur  
            if pregnancy, menopause, or osteoporosis casually related to  
            menopause is  contemporaneous  with the physical injury. The  
            Merriam-Webster dictionary defines contemporaneous as  
            "existing or happening during the same time period". For  
            specific injuries, such as a fall or a car accident, this  
            could be a straight forward analysis: a doctor would simply  
            exclude pregnancy, menopause, or osteoporosis from his or her  
            apportionment determination.

            For injuries that are the product of cumulative trauma,  
            however, this may be a more complicated analysis. For  
            cumulative trauma injuries, existing law requires that the  
            injured worker must file a workers' compensation a year from  
            when the worker knew or should have known that the cumulative  
            trauma injury was caused by work. It is unclear how AB 305  
            would impact apportionment with cumulative trauma injuries.







          AB 305 (Gonzalez)                                       Page 7  
          of ?
          

            Would, for example, menopause being considered contemporaneous  
            if it existed at the time of the filing? Or would the injured  
            worker need to prove that she was going through menopause  
            during employment? What if the worker was going through  
            menopause but not osteoporosis during employment, but had  
            osteoporosis at the time of filing a claim? Likely, these are  
            fact-intensive analyses which may be clarified by future WCAB  
            decisions, which would necessitate significant litigation.  
            Therefore, it is likely that AB 305 would increase litigation  
            costs for employers, particularly in the area of cumulative  
            trauma claims.

            Enshrining Gender Discrimination into the Workers'  
            Compensation System

            Currently, California's workers' compensation system does not  
            treat different groups of injured workers differently than  
            others. As was noted above, the AMA Guides look solely at  
            impairment; PD is awarded on the severity of injury. While  
            adjustments may be made for occupation and age, there are no  
            adjustments for race, gender, or religion. AB 305 changes that  
            by excluding from apportionment conditions that are specific  
            to women, despite the fact that some male injured workers may  
            experience similar conditions. 

            For example, according to the National Osteoporosis Foundation  
            (NOF), up to 25% of all men over 50 may have osteoporosis -  
            and men over 50 are more likely to break a bone due to  
            osteoporosis than get prostate cancer. Currently, both men and  
            women could have their PD apportioned if osteoporosis was a  
            non-industrial cause of injury. Under AB 305, however, women  
            would be able to litigate that their menopause (which,  
            according to NOF is only a risk factor for osteoporosis, not  
            determinative) caused their osteoporosis, and therefore is  
            non-industrial. Under AB 305, a male injured worker would have  
            few to no legal avenues to contest the apportionment of his  
            osteoporosis. 

            By creating a gender disparity for male and female injured  
            workers, AB 305 may adversely impact some male injured workers  
            and undermine the equity of the workers' compensation system.

          4.  An Additional Note on Apportionment:
           







          AB 305 (Gonzalez)                                       Page 8  
          of ?
          
            As was discussed above, AB 305 faces significant  
            implementation. However, that does not mean that apportionment  
            in and of itself is a policy that does not need additional  
            legislative scrutiny. Rather, it may be time for a larger  
            stakeholder discussion on if apportionment works as intended.

            Surprisingly, there has been little recent study on  
            apportionment. The last study on the impact of apportionment  
            was done by the WCIRB in 2008, and that study found that about  
            6% of all PD dollars were apportioned. However, there have  
            been significant increases in indemnity payments and  
            litigation frequency, as well as loss-adjusted expenses (LAE),  
            which tends to be a proxy for litigation costs. 

            Noting the strong evidence that apportionment is more likely  
            in litigated cases, the current impact of apportionment on PD  
            claims and dollars is an important policy question, and it is  
            a policy question about which we know very, very little. Does  
            apportionment still reduce PD dollars by 6%, or has it  
            increased? Does apportionment make litigation more likely? Or  
            does litigation make apportionment more likely? And would  
            apportionment change the way either an applicant or defendant  
            would litigate the case?

            More fundamentally, however, there is an even more basic  
            question with apportionment: does it actually save money, or  
            is it a cost driver? If apportionment increases the likelihood  
            of litigation or makes litigation more severe, it is possible  
            that it actually serves as a cost driver in the system - one  
            that is automatic with the physician's completion of a PD  
            report. While this is very unlikely, the reality is that we  
            simply do not know the full impacts of apportionment.

            Noting the significance of apportionment for employers and  
            injured workers, stakeholders may wish to consider requesting  
            that the Commission on Health and Safety and Workers'  
            Compensation (CHSWC) authorize a study on the current impacts  
            of apportionment on litigation and PD dollars.
          
          5.  AB 305 and Retroactivity:  

            When AB 305 was heard in the Assembly Insurance Committee on  
            May 5, 2015, both members and stakeholders raised concerns  
            about AB 305 and the possibility of retroactive application of  
            its provisions. At that time, Assemblymember Gonzalez said  







          AB 305 (Gonzalez)                                       Page 9  
          of ?
          
            that was not her intent and committed to future amendments. AB  
            305 was amended on June 15, 2015, removing the retroactive  
            provisions. The author's office stated that the purpose of the  
            amendments was to eliminate the possibility of retroactive  
            application of AB 305's provisions, and the sponsor's letter  
            also states the same. 

            Therefore, noting the strong legislative intent, it is  
            unlikely that a court would find that the provisions of AB 305  
            are retroactive. The Committee may wish to further clarify  
            this point by considering the following amendment, which would  
            make AB 305's apportionment provisions apply to injuries on or  
            after January 1, 2016. 

            On page 6, page 1, strike "Apportionment" and insert: "For  
            injuries occurring on or after January 1, 2016,  
            apportionment".




          6.  Proponent Arguments  :
            
            The sponsor of this bill, the California Applicants' Attorneys  
            Association (CAAA), argues that AB 305 will eliminate gender  
            bias from apportionment when determining permanent disability  
            ratings. CAAA argues that factors such as pregnancy and  
            menopause are used as factors to lower permanent disability.  
            CAAA also cites several cases where apportionment is purported  
            to have occurred due to risk factors and immutable  
            characteristics, rather than proven conditions. CAAA also  
            notes that AB 305 will make breast cancer eligible for the  
            same disability rating as prostate cancer. Finally, CAAA  
            argues that the workers' compensation system treats being a  
            woman as a pre-existing condition, and that AB 305 will ensure  
            that women receive the level of permanent disability they  
            deserve.

          7.  Opponent Arguments  :

            Opponents argue that AB 305 is an attempt to undermine an  
            employer's use of apportionment when determining liability for  
            permanent disability awards. Specifically, opponents note that  
            apportionment is more than a decade old and ensures that  
            employers do not need to pay for non-industrial injuries.  







          AB 305 (Gonzalez)                                       Page 10  
          of ?
          
            Further, opponents point to case law and statute which  
            protects injured workers from abusive apportionment, including  
            apportionment on the basis of gender. Opponents further argue  
            that AB 305 will increase litigation, raise indemnity costs on  
            employers, and increase systemic instability and subjectivity.

          8.  Prior Legislation  :

            AB 1155 (Alejo) of 2011 addressed apportionment by broadly  
            prohibiting the use of the protected classes defined in the  
            Unruh Civil Rights Act as a basis to apportion permanent  
            disability awards. AB 1155 was vetoed by Governor Brown, who  
            said the following is his veto message:

            The courts already recognize that apportioning a disability  
            award to any of these classifications is antithetical to our  
            states' non-discrimination policies. The courts also recognize  
            that apportioning to an actual non-industrial condition that  
            contributes to causing a disability is permissible and  
            required by the principle that apportionment is based on  
            causation. 

          This bill would not change existing law as interpreted by the  
            courts to date. This bill would, however, generate new  
            litigation over questions of whether it is intended to change  
            existing interpretations. At best, that additional litigation  
            would add to employers' costs for workers' compensation. At  
            worst, this bill could disturb the appropriate interpretation  
            of existing law that is already taking shape in the courts.



          SUPPORT
          

          California Applicant's Attorneys (co-sponsor)
          California Teamsters Public Affairs Council (co-sponsor)
          American Association of University Women - AAUW of CA
          American Federation of State, County and Municipal Employees,  
          AFL-CIO
          California Conference Board of the Amalgamated Transit Union
          California Conference of Machinists
          California Nurses Association 
          California Professional Firefighters 
          California School Employees Association, AFL-CIO







          AB 305 (Gonzalez)                                       Page 11  
          of ?
                
          California State Lodge, Fraternal Order of Police
          Engineers & Scientists of California
          International Longshore & Warehouse Union
          LA County Professional Peace Officers Association
          Long Beach Police Officers Association
          Los Angeles County Professional Peace Officers Association
          Organization of SMUD Employees
          Peace Officers Research Association of California 
          Professional & Technical Engineers
          Sacramento County Deputy Sheriffs' Association
          San Bernardino Public Employees Association
          San Diego County Court Employees Association
          San Luis Obispo County Employees Association
          Santa Ana Police Officers Association 
          The United Nurses Association of California
          Union of Health Care Professionals
          United Food & Commercial Workers
          UNITE-HERE, AFL-CIO
          Utility Workers Union of America
          9to5 of California
          

          OPPOSITION
          

          Acclamation Insurance Management Services
          Allied Managed Care
          American Insurance Association 
          Association of California Insurance Companies
          Association of California Water Agencies
          California Association of Joint Powers Authorities
          California Chamber of Commerce
          California Coalition on Workers' Compensation
          California Grocers Association
          California League of Food Processors
          California Manufacturers and Technology Association
          California Retailers Association 
          California State Association of Counties
          County of Los Angeles
          CSAC Excess Insurance Authority
          Independent Insurance Agents and Brokers of California
          League of California Cities
          Marin County Board of Supervisors
          Torrance Area Chamber of Commerce
          Western Occupational & Environmental Medical Association







          AB 305 (Gonzalez)                                       Page 12  
          of ?
          


                                      -- END --