Slater v. SAIF

Under ORS 656.245(1)(a)), Insurers “are responsible for medical services ‘for conditions'—that is, ordinary conditions—that are ‘caused in material part’ by compensable workplace injuries.” SAIF v. Sprague, 346 Or 661, 664, 217 P3d 644 (2009).

Claimant appealed the Workers’ Compensation Board’s (the Board) decision that denied medical services and treatment for injuries sustained to his left knee while working for an organization insured by Defendant. On appeal, Claimant assigned error to the Board’s recognition of his doctor’s opinion of his injuries as “preexisting” to sufficiently meet the Defendant’s burden of proof that a preexisting condition is the major contributing cause of Claimant’s combined condition. In response, Defendant argued that the medical evidence it received as a whole supported the board’s conclusion that the doctor’s description of the Claimant’s symptoms was synonymous with a preexisting condition. Under ORS 656.245(1)(a)), Insurers “are responsible for medical services ‘for conditions'—that is, ordinary conditions—that are ‘caused in material part’ by compensable workplace injuries.” SAIF v. Sprague, 346 Or 661, 664 (2009) (quoting ORS 656.245(1)(a)). The Court of Appeals held the Board erred in denying medical services and treatment because the Board did not address whether the medical treatments were to be directed towards the combined condition or to another condition caused in material part by the work-related injury. Reversed.