Uninsured Employer's Fund v. Wilson

KELSEY, Judge.

The Uninsured Employer’s Fund seeks a credit against medical benefits owed under the Virginia Workers’ Compensation Act for payments made to the claimant pursuant to an out-of-state settlement that had not been submitted to the Virginia Workers’ Compensation Commission for approval. The commission denied the credit, reasoning that Code § 65.2-520 authorizes credits only against compensation payments, not medical benefits. We agree and affirm.

I

Michael Lewis Wilson, a Michigan resident, worked for George Kountoupes Painting Co. His employer, also based in Michigan, hired Wilson to…