Worker Had 'Earning Power' Despite Inability to Secure Job

The Commonwealth Court ruled that an employer was entitled to a modification of its payment of benefits to a worker who was unable to obtain any of the positions identified though a labor market survey. Case: Valenta v. WCAB (Abington Manor Nursing Home and Rehab), No. 1302 C.D. 2016, 12/07/2017, published. Facts and procedural history: Laurie Valenta began collecting total disability benefits in September 2012 for injuries to her back and shoulders. In 2014, her former employer’s comp carrier ordered a labor market survey and earning power assessment for Valenta. The LMS and EPA loca...