WCLA MCLE

bull WCLA MCLE Year End Wrap Up amp Legislative Update

bull Thursday December 2 2010bull 1200 pm to 100 pmbull James R Thompson Center Auditorium

Chicago ILbull 1 Hour General MCLE Credit

Temporary Partial Disabilitybull Dyan McBride v State of IL 09IWCC0914bull DA 6-13-06bull 52 yo mental health technician sustains fractures to right arm resulting from fallbull Prior to injury ldquoregularly worked voluntary overtimerdquobull 52 weeks prior to DA $2862912 straight (AWW $55056) + $954807 total OT

($18362week)bull RTW light duty 6-19-06 doing paperwork but no OT RTW full duty 10-1-06bull Full capacity = Gross straight time actually earned ($936860)+ average weekly OT

($18362week or $2570 total) = $11 93928bull TPD = 23($11 93928 - $626645 actual net earnings)= 23( $567283) = $378188bull ldquoSection 8(a) of the Act regarding TPD places none of the AWW limitations found

in Section 10 of the Act regarding OT nor does it limit the OT to the straight time raterdquo

bull Credit based on weeks paid not paid under old schedule

Temporary Partial Disability

bull Copperweld Tubing 402 Ill App 3d 630 8(d)1 vacated amp remanded to Commission with instruction to omit ldquoevidence properly excluded by Section 10 of the Actrdquo (voluntary overtime) Any impact on calculation of TPD

bull Temporary partial disability benefits shall be equal to two-thirds of the difference between the average amount that the employee would be able to earn in the full performance of his or her duties in the occupation in which he or she was engaged at the time of the accident and the net amount which he or she is earning in the modified job provided to the employee by the employerrdquo

bull Anybody have a case

Interstate Scaffoldingbull Steele v Kelly Services 06WC46872 10 IWCC 949 NO TTD ldquoFurther Ms Gardner

testified that restricted duty is available at Kelly Services and has been from September 2006 through the present Ms Gardner testified that restricted duty is within the Kelly Services office and can be sedentary no lifting pushing pulling bending or stooping An employee may sit or stand as needed While the petitioner has various periods during which he has been placed under restrictions the petitioner did not present to Kelly Services seeking employment within those restrictions The Arbitrator takes into consideration the recent decision in Interstate Scaffolding wherein the court found that if employment is terminated for an unrelated cause and the claimants condition has not yet stabilized TTD is due and owing However the Arbitrator notes the respondent in this matter did not terminate the petitioner the petitioner voluntarily left his employment An employer cannot be held responsible when an employee refuses to appear for work and voluntarily abandons their jobrdquo Affirmed by unanimous IWCC

bull See also Gill v Meany Inc 09WC24525 10 IWCC 0935 voluntary retirement cuts off TTD

Greene Welding (amputations)bull Alejandro Garcia v River Docks 08WC 42973 10 IWCC 837 ldquoFurther where the claimant suffers clear

unquestionable statutory amputations with no existing dispute the Respondents delay in payment warrants an assessment of penalties under Section 19(k) and attorneys fees under Section 16 of the Workers Compensation Act See Kinnaird v Greene Welding amp Hardware 08 IWCC 0812 Lester v Industrial Commission 256 IllApp3d 520 In the case at bar the claimant suffered clear indisputable traumatic amputations of the right 4th and 5th digits at the scene of the occurrence on July 31 2008 when his severed little finger and ring finger were placed on ice accompanying Petitioner to University of Chicago Hospitals same day at which time surgeons performed an unsuccessful replantation of the right ring finger On August 12 2008 Dr Ginard Henry primary surgeon performed a second surgical procedure which was a completion amputation of the failed right 4th digit replantation along with other right hand surgery At this point in time Respondent was clearly aware that the Petitioner had complete loss by traumatic amputation of his right 4th and 5th digits However Respondent unreasonably failed to immediately pay to Petitioner permanent partial disability compensation of 100 for each of those digits pursuant to Section 8(e) It was not until March 10 2009 a check was issued to claimant Alejandro Garcia in the sum of $ 1278263 In the Kinnaird Decision where Section 19(k) penalties and attorneys fees under Section 16 were awarded the Petitioner had returned to work 2 37 weeks following the traumatic amputations but the Respondent did not pay for the statutory amputations before an additional month had passed a total of 6 37 weeks having elapsed from the date of the traumatic amputations In contrast in the case at bar Respondent did not pay the statutory amputation benefits to Mr Garcia as required by Section 8(e) of the Act until over approximately 30 weeks following August 12 2008 at which time the date upon which the Respondent had become clearly aware Petitioner had suffered traumatic amputations of the 4th and 5th digits of his right hand

Temporary Partial Disabilitybull Dyan McBride v State of IL 09IWCC0914bull DA 6-13-06bull 52 yo mental health technician sustains fractures to right arm resulting from fallbull Prior to injury ldquoregularly worked voluntary overtimerdquobull 52 weeks prior to DA $2862912 straight (AWW $55056) + $954807 total OT

($18362week)bull RTW light duty 6-19-06 doing paperwork but no OT RTW full duty 10-1-06bull Full capacity = Gross straight time actually earned ($936860)+ average weekly OT

($18362week or $2570 total) = $11 93928bull TPD = 23($11 93928 - $626645 actual net earnings)= 23( $567283) = $378188bull ldquoSection 8(a) of the Act regarding TPD places none of the AWW limitations found

in Section 10 of the Act regarding OT nor does it limit the OT to the straight time raterdquo

bull Credit based on weeks paid not paid under old schedule

Temporary Partial Disability

bull Copperweld Tubing 402 Ill App 3d 630 8(d)1 vacated amp remanded to Commission with instruction to omit ldquoevidence properly excluded by Section 10 of the Actrdquo (voluntary overtime) Any impact on calculation of TPD

bull Temporary partial disability benefits shall be equal to two-thirds of the difference between the average amount that the employee would be able to earn in the full performance of his or her duties in the occupation in which he or she was engaged at the time of the accident and the net amount which he or she is earning in the modified job provided to the employee by the employerrdquo

bull Anybody have a case

Interstate Scaffoldingbull Steele v Kelly Services 06WC46872 10 IWCC 949 NO TTD ldquoFurther Ms Gardner

testified that restricted duty is available at Kelly Services and has been from September 2006 through the present Ms Gardner testified that restricted duty is within the Kelly Services office and can be sedentary no lifting pushing pulling bending or stooping An employee may sit or stand as needed While the petitioner has various periods during which he has been placed under restrictions the petitioner did not present to Kelly Services seeking employment within those restrictions The Arbitrator takes into consideration the recent decision in Interstate Scaffolding wherein the court found that if employment is terminated for an unrelated cause and the claimants condition has not yet stabilized TTD is due and owing However the Arbitrator notes the respondent in this matter did not terminate the petitioner the petitioner voluntarily left his employment An employer cannot be held responsible when an employee refuses to appear for work and voluntarily abandons their jobrdquo Affirmed by unanimous IWCC

bull See also Gill v Meany Inc 09WC24525 10 IWCC 0935 voluntary retirement cuts off TTD

Greene Welding (amputations)bull Alejandro Garcia v River Docks 08WC 42973 10 IWCC 837 ldquoFurther where the claimant suffers clear

unquestionable statutory amputations with no existing dispute the Respondents delay in payment warrants an assessment of penalties under Section 19(k) and attorneys fees under Section 16 of the Workers Compensation Act See Kinnaird v Greene Welding amp Hardware 08 IWCC 0812 Lester v Industrial Commission 256 IllApp3d 520 In the case at bar the claimant suffered clear indisputable traumatic amputations of the right 4th and 5th digits at the scene of the occurrence on July 31 2008 when his severed little finger and ring finger were placed on ice accompanying Petitioner to University of Chicago Hospitals same day at which time surgeons performed an unsuccessful replantation of the right ring finger On August 12 2008 Dr Ginard Henry primary surgeon performed a second surgical procedure which was a completion amputation of the failed right 4th digit replantation along with other right hand surgery At this point in time Respondent was clearly aware that the Petitioner had complete loss by traumatic amputation of his right 4th and 5th digits However Respondent unreasonably failed to immediately pay to Petitioner permanent partial disability compensation of 100 for each of those digits pursuant to Section 8(e) It was not until March 10 2009 a check was issued to claimant Alejandro Garcia in the sum of $ 1278263 In the Kinnaird Decision where Section 19(k) penalties and attorneys fees under Section 16 were awarded the Petitioner had returned to work 2 37 weeks following the traumatic amputations but the Respondent did not pay for the statutory amputations before an additional month had passed a total of 6 37 weeks having elapsed from the date of the traumatic amputations In contrast in the case at bar Respondent did not pay the statutory amputation benefits to Mr Garcia as required by Section 8(e) of the Act until over approximately 30 weeks following August 12 2008 at which time the date upon which the Respondent had become clearly aware Petitioner had suffered traumatic amputations of the 4th and 5th digits of his right hand

Temporary Partial Disability

bull Copperweld Tubing 402 Ill App 3d 630 8(d)1 vacated amp remanded to Commission with instruction to omit ldquoevidence properly excluded by Section 10 of the Actrdquo (voluntary overtime) Any impact on calculation of TPD

bull Temporary partial disability benefits shall be equal to two-thirds of the difference between the average amount that the employee would be able to earn in the full performance of his or her duties in the occupation in which he or she was engaged at the time of the accident and the net amount which he or she is earning in the modified job provided to the employee by the employerrdquo

bull Anybody have a case

Interstate Scaffoldingbull Steele v Kelly Services 06WC46872 10 IWCC 949 NO TTD ldquoFurther Ms Gardner

testified that restricted duty is available at Kelly Services and has been from September 2006 through the present Ms Gardner testified that restricted duty is within the Kelly Services office and can be sedentary no lifting pushing pulling bending or stooping An employee may sit or stand as needed While the petitioner has various periods during which he has been placed under restrictions the petitioner did not present to Kelly Services seeking employment within those restrictions The Arbitrator takes into consideration the recent decision in Interstate Scaffolding wherein the court found that if employment is terminated for an unrelated cause and the claimants condition has not yet stabilized TTD is due and owing However the Arbitrator notes the respondent in this matter did not terminate the petitioner the petitioner voluntarily left his employment An employer cannot be held responsible when an employee refuses to appear for work and voluntarily abandons their jobrdquo Affirmed by unanimous IWCC

bull See also Gill v Meany Inc 09WC24525 10 IWCC 0935 voluntary retirement cuts off TTD

Greene Welding (amputations)bull Alejandro Garcia v River Docks 08WC 42973 10 IWCC 837 ldquoFurther where the claimant suffers clear

unquestionable statutory amputations with no existing dispute the Respondents delay in payment warrants an assessment of penalties under Section 19(k) and attorneys fees under Section 16 of the Workers Compensation Act See Kinnaird v Greene Welding amp Hardware 08 IWCC 0812 Lester v Industrial Commission 256 IllApp3d 520 In the case at bar the claimant suffered clear indisputable traumatic amputations of the right 4th and 5th digits at the scene of the occurrence on July 31 2008 when his severed little finger and ring finger were placed on ice accompanying Petitioner to University of Chicago Hospitals same day at which time surgeons performed an unsuccessful replantation of the right ring finger On August 12 2008 Dr Ginard Henry primary surgeon performed a second surgical procedure which was a completion amputation of the failed right 4th digit replantation along with other right hand surgery At this point in time Respondent was clearly aware that the Petitioner had complete loss by traumatic amputation of his right 4th and 5th digits However Respondent unreasonably failed to immediately pay to Petitioner permanent partial disability compensation of 100 for each of those digits pursuant to Section 8(e) It was not until March 10 2009 a check was issued to claimant Alejandro Garcia in the sum of $ 1278263 In the Kinnaird Decision where Section 19(k) penalties and attorneys fees under Section 16 were awarded the Petitioner had returned to work 2 37 weeks following the traumatic amputations but the Respondent did not pay for the statutory amputations before an additional month had passed a total of 6 37 weeks having elapsed from the date of the traumatic amputations In contrast in the case at bar Respondent did not pay the statutory amputation benefits to Mr Garcia as required by Section 8(e) of the Act until over approximately 30 weeks following August 12 2008 at which time the date upon which the Respondent had become clearly aware Petitioner had suffered traumatic amputations of the 4th and 5th digits of his right hand

Interstate Scaffoldingbull Steele v Kelly Services 06WC46872 10 IWCC 949 NO TTD ldquoFurther Ms Gardner

testified that restricted duty is available at Kelly Services and has been from September 2006 through the present Ms Gardner testified that restricted duty is within the Kelly Services office and can be sedentary no lifting pushing pulling bending or stooping An employee may sit or stand as needed While the petitioner has various periods during which he has been placed under restrictions the petitioner did not present to Kelly Services seeking employment within those restrictions The Arbitrator takes into consideration the recent decision in Interstate Scaffolding wherein the court found that if employment is terminated for an unrelated cause and the claimants condition has not yet stabilized TTD is due and owing However the Arbitrator notes the respondent in this matter did not terminate the petitioner the petitioner voluntarily left his employment An employer cannot be held responsible when an employee refuses to appear for work and voluntarily abandons their jobrdquo Affirmed by unanimous IWCC

bull See also Gill v Meany Inc 09WC24525 10 IWCC 0935 voluntary retirement cuts off TTD

Greene Welding (amputations)bull Alejandro Garcia v River Docks 08WC 42973 10 IWCC 837 ldquoFurther where the claimant suffers clear

unquestionable statutory amputations with no existing dispute the Respondents delay in payment warrants an assessment of penalties under Section 19(k) and attorneys fees under Section 16 of the Workers Compensation Act See Kinnaird v Greene Welding amp Hardware 08 IWCC 0812 Lester v Industrial Commission 256 IllApp3d 520 In the case at bar the claimant suffered clear indisputable traumatic amputations of the right 4th and 5th digits at the scene of the occurrence on July 31 2008 when his severed little finger and ring finger were placed on ice accompanying Petitioner to University of Chicago Hospitals same day at which time surgeons performed an unsuccessful replantation of the right ring finger On August 12 2008 Dr Ginard Henry primary surgeon performed a second surgical procedure which was a completion amputation of the failed right 4th digit replantation along with other right hand surgery At this point in time Respondent was clearly aware that the Petitioner had complete loss by traumatic amputation of his right 4th and 5th digits However Respondent unreasonably failed to immediately pay to Petitioner permanent partial disability compensation of 100 for each of those digits pursuant to Section 8(e) It was not until March 10 2009 a check was issued to claimant Alejandro Garcia in the sum of $ 1278263 In the Kinnaird Decision where Section 19(k) penalties and attorneys fees under Section 16 were awarded the Petitioner had returned to work 2 37 weeks following the traumatic amputations but the Respondent did not pay for the statutory amputations before an additional month had passed a total of 6 37 weeks having elapsed from the date of the traumatic amputations In contrast in the case at bar Respondent did not pay the statutory amputation benefits to Mr Garcia as required by Section 8(e) of the Act until over approximately 30 weeks following August 12 2008 at which time the date upon which the Respondent had become clearly aware Petitioner had suffered traumatic amputations of the 4th and 5th digits of his right hand

Greene Welding (amputations)bull Alejandro Garcia v River Docks 08WC 42973 10 IWCC 837 ldquoFurther where the claimant suffers clear

unquestionable statutory amputations with no existing dispute the Respondents delay in payment warrants an assessment of penalties under Section 19(k) and attorneys fees under Section 16 of the Workers Compensation Act See Kinnaird v Greene Welding amp Hardware 08 IWCC 0812 Lester v Industrial Commission 256 IllApp3d 520 In the case at bar the claimant suffered clear indisputable traumatic amputations of the right 4th and 5th digits at the scene of the occurrence on July 31 2008 when his severed little finger and ring finger were placed on ice accompanying Petitioner to University of Chicago Hospitals same day at which time surgeons performed an unsuccessful replantation of the right ring finger On August 12 2008 Dr Ginard Henry primary surgeon performed a second surgical procedure which was a completion amputation of the failed right 4th digit replantation along with other right hand surgery At this point in time Respondent was clearly aware that the Petitioner had complete loss by traumatic amputation of his right 4th and 5th digits However Respondent unreasonably failed to immediately pay to Petitioner permanent partial disability compensation of 100 for each of those digits pursuant to Section 8(e) It was not until March 10 2009 a check was issued to claimant Alejandro Garcia in the sum of $ 1278263 In the Kinnaird Decision where Section 19(k) penalties and attorneys fees under Section 16 were awarded the Petitioner had returned to work 2 37 weeks following the traumatic amputations but the Respondent did not pay for the statutory amputations before an additional month had passed a total of 6 37 weeks having elapsed from the date of the traumatic amputations In contrast in the case at bar Respondent did not pay the statutory amputation benefits to Mr Garcia as required by Section 8(e) of the Act until over approximately 30 weeks following August 12 2008 at which time the date upon which the Respondent had become clearly aware Petitioner had suffered traumatic amputations of the 4th and 5th digits of his right hand

Greene Welding (cont)bull Garcia cont ldquoFurther AIG Claim Services representing Respondent in the case at bar addressed the Petitioners

attorney under fax dated March 9 2009 contrary to black letter law advised As your client was deemed MMI please prepare and forward your settlement demand to conclude this matterldquo This ignorance of the law was inexcusable and deprived Petitioner of his full Workers Compensation benefits That same argument contending statutory amputation benefits need not be paid until Petitioner was MMI was made by another Respondent in Lester contending that payment was not due regarding a statutory amputation until the claimant has reached maximum medical improvement In rejecting this argument the Illinois Appellate Court in Lester stated it was the intent of the Legislature that an employee who suffers amputation should be compensated immediately when no dispute exists as to the liability of the accident that ruled recently in Kinnaird See LesterHowever the Respondent further ignored applicable Workers Compensation Statutory Law there being a provision in effect on the date of occurrence July 31 2008 a change effective since February 1 2006 providing under 820 ILCS 3058(b)41 Minimum Rate for Amputation of a Member under Section 8(e) is increased to 50 of SAWW The SAWW at the time of the accidental injury to the Petitioner July 31 2008 was $ 91256 and 50 of that number produces a minimum PPD rate of $ 45628 which PPD rate is higher than the PPD rate as extended against Petitioners AWW of $ 58126 per weekRespondent clearly demonstrated unreasonable and vexatious behavior by carelessly making a late payment for statutory amputation benefits when the law was clear on this point As such applying the minimum rate for amputation pursuant to 820 ILCS 3058(b) 41 establishing an appropriate PPD rate of $ 45628 produces a total for amputation benefits in the amount of $ 2235772 Respondent paid a total of $ 1278263 resulting in an underpayment of $ 957509rdquo

Dismissal amp Reinstatement

bull TTC Illinois 396 Ill App 3d 344 (2010) technical compliance with reinstatement rule not required case reinstated after 21 months

bull Alejandro Rodriguez v Total Doors 05WC037659 10 IWCC 772 DA 6-20-05 Filed 8-26-05 Dismissed 12-16-08 Petition to Reinstate filed 3-3-09 (notice received 1-10-09) NOM for 4-6-09 Respondent filed Motion to Dismiss Petition to Reinstate12-24-09 Granted 1-13-10 Affirmed 8-12-10 ldquolack of due diligencerdquo Respondentrsquos request for fees denied

Intervening Injuries

bull Menard v IWCC No5-09-0354WC filed 11-16-10

bull 4-1-99 Application filed for anxietymental illness caused by conflicts at work

bull Petitioner firedbull 2-20-00 Petitioner falls while attending IMEbull 1-24-03 files 2nd App for fall

Menard (cont)

bull Arbitrator awards benefits for mental-mental case and for IME fall

bull Commission reverses mental-mental case but affirms IME fall finding Petitioner was under the direction of the employer even though she had been fired

bull Circuit Court of Jackson County reverses No employer employee relationship existed

bull Appellate Court affirms citing Skelgas attendance at IME was not a condition of the employment

Other Issues

bull Uninsured employers Keating hearings pending before IWCC rules to follow Anybody have a case

bull Medical records subpoenas Has the Holtkamp Trucking crisis blown over Anybody have a Holtkamp experience

Legislative Update

bull Senate amp House Special Committees on Workersrsquo Compensation Reform

bull Changing standard of causation (no more aggravation of pre-existing condition)

bull AMA guidelines for PPDbull Binding utilization reviewbull Wage-differentials (change in economic circumstances prior

credit cap at retirement age)bull Alcohol amp drugsbull Choice of medical bull Collectively bargained workersrsquo compensation

• WCLA MCLE
• Temporary Partial Disability
• Slide 3
• Interstate Scaffolding
• Greene Welding (amputations)
• Greene Welding (cont)
• Dismissal amp Reinstatement
• Intervening Injuries
• Menard (cont)
• Other Issues
• Legislative Update

Intervening Injuries

bull Menard v IWCC No5-09-0354WC filed 11-16-10

bull 4-1-99 Application filed for anxietymental illness caused by conflicts at work

bull Petitioner firedbull 2-20-00 Petitioner falls while attending IMEbull 1-24-03 files 2nd App for fall

Menard (cont)

bull Arbitrator awards benefits for mental-mental case and for IME fall

bull Commission reverses mental-mental case but affirms IME fall finding Petitioner was under the direction of the employer even though she had been fired

bull Circuit Court of Jackson County reverses No employer employee relationship existed

bull Appellate Court affirms citing Skelgas attendance at IME was not a condition of the employment

Other Issues

bull Uninsured employers Keating hearings pending before IWCC rules to follow Anybody have a case

bull Medical records subpoenas Has the Holtkamp Trucking crisis blown over Anybody have a Holtkamp experience

Legislative Update

bull Senate amp House Special Committees on Workersrsquo Compensation Reform

bull Changing standard of causation (no more aggravation of pre-existing condition)

bull AMA guidelines for PPDbull Binding utilization reviewbull Wage-differentials (change in economic circumstances prior

credit cap at retirement age)bull Alcohol amp drugsbull Choice of medical bull Collectively bargained workersrsquo compensation

• WCLA MCLE
• Temporary Partial Disability
• Slide 3
• Interstate Scaffolding
• Greene Welding (amputations)
• Greene Welding (cont)
• Dismissal amp Reinstatement
• Intervening Injuries
• Menard (cont)
• Other Issues
• Legislative Update

Menard (cont)

bull Arbitrator awards benefits for mental-mental case and for IME fall

bull Commission reverses mental-mental case but affirms IME fall finding Petitioner was under the direction of the employer even though she had been fired

bull Circuit Court of Jackson County reverses No employer employee relationship existed

bull Appellate Court affirms citing Skelgas attendance at IME was not a condition of the employment

Other Issues

bull Uninsured employers Keating hearings pending before IWCC rules to follow Anybody have a case

bull Medical records subpoenas Has the Holtkamp Trucking crisis blown over Anybody have a Holtkamp experience

Legislative Update

bull Senate amp House Special Committees on Workersrsquo Compensation Reform

bull Changing standard of causation (no more aggravation of pre-existing condition)

bull AMA guidelines for PPDbull Binding utilization reviewbull Wage-differentials (change in economic circumstances prior

credit cap at retirement age)bull Alcohol amp drugsbull Choice of medical bull Collectively bargained workersrsquo compensation

• WCLA MCLE
• Temporary Partial Disability
• Slide 3
• Interstate Scaffolding
• Greene Welding (amputations)
• Greene Welding (cont)
• Dismissal amp Reinstatement
• Intervening Injuries
• Menard (cont)
• Other Issues
• Legislative Update

Other Issues

bull Uninsured employers Keating hearings pending before IWCC rules to follow Anybody have a case

bull Medical records subpoenas Has the Holtkamp Trucking crisis blown over Anybody have a Holtkamp experience

Legislative Update

bull Senate amp House Special Committees on Workersrsquo Compensation Reform

bull Changing standard of causation (no more aggravation of pre-existing condition)

bull AMA guidelines for PPDbull Binding utilization reviewbull Wage-differentials (change in economic circumstances prior

credit cap at retirement age)bull Alcohol amp drugsbull Choice of medical bull Collectively bargained workersrsquo compensation

• WCLA MCLE
• Temporary Partial Disability
• Slide 3
• Interstate Scaffolding
• Greene Welding (amputations)
• Greene Welding (cont)
• Dismissal amp Reinstatement
• Intervening Injuries
• Menard (cont)
• Other Issues
• Legislative Update

Legislative Update

bull Senate amp House Special Committees on Workersrsquo Compensation Reform

bull Changing standard of causation (no more aggravation of pre-existing condition)

bull AMA guidelines for PPDbull Binding utilization reviewbull Wage-differentials (change in economic circumstances prior

credit cap at retirement age)bull Alcohol amp drugsbull Choice of medical bull Collectively bargained workersrsquo compensation

• WCLA MCLE
• Temporary Partial Disability
• Slide 3
• Interstate Scaffolding
• Greene Welding (amputations)
• Greene Welding (cont)
• Dismissal amp Reinstatement
• Intervening Injuries
• Menard (cont)
• Other Issues
• Legislative Update