State Compensation Insurance Authority v. Smith

PLANK, Judge.

The questions presented for review in this workmen’s compensation proceeding are whether the computation of an injured employee’s average weekly wage, for purposes of temporary disability benefits, may include the cost of employer provided health insurance and, if so, whether the inclusion of such insurance in the average weekly wage should be the premium cost to the employer or the amount it would cost the employee to convert to an individual plan. We hold that if employer-provided health insurance is discontinued while an employee is temporarily disabled, the cost of the health…