SAIF Corporation v. Stephens

When a claim is determined to be a symptom rather than a condition, the employer is not required to admit the symptom as a new or omitted medical condition.

SAIF seeks review of the Workers’ Compensation Board’s decision finding that Claimant’s coccydynia was compensable as a new or omitted medical condition. Claimant, while working as a caregiver, fell, resulting in pain in her coccyx. SAIF accepted Claimant’s first claim for lumbar contusion and lumbar strain and did not award permanent partial disability. It also accepted Claimant’s second request to recognize the medical condition coccydynia and closed without awarding additional disability. The board found that SAIF’s amended notice of acceptance was not sufficient. The Court of Appeals found that the board’s determination regarding SAIF’s obligation to process was correct. The question for the Court was whether a reasonable person could determine that coccydynia is a condition. Based on the record, the Court found that coccydynia is a symptom, not a condition; and that the board thus erred in their determination. Based on the confusing nature of this law, SAIF’s failure to respond by denying the condition was not unreasonable. Reversed.