Rhoades v. Department of Labor & Industries

*835¶1 If a worker becomes entitled to a pension as a result of being adjudged permanently totally disabled after having received a lump sum for a permanent partial disability, the Department of Labor and Industries (Department) treats the previously paid award as an advance on the pension. Trayle v. Dep’t of Labor & Indus., 70 Wn.2d 141, 422 P.2d 520 (1967). The Department therefore deducts the amount of the lump sum award from the worker’s pension reserve, resulting in a corresponding reduction in monthly pension payments. RCW 51.32.080(4). The annuity value of a worker’s pension is based on…