High Court Clarifies PPD Benefit Rate Calculation for Workers With Concurrent Jobs

The Montana Supreme Court decided that the Workers' Compensation Court erred when it ruled that a permanently partially disabled worker's aggregate wages, calculated at the time of injury, are used to determine the permanent partial disability benefit rate regardless of actual wage loss at maximum healing. Case: Barnhart v. Montana State Fund, No. DA 22-0114, 12/27/2022, published. Facts: Tamara Barnhart suffered a back injury in the course of her employment with Youth Dynamics Inc. in 2017. She worked an average of 40.6 hours per week at YDI. She also worked an average of 15.2 ...