Lewis v. Trimble

This appeal raises two important issues under Ohio’s workers’ compensation law. The first issue involves the application and requirements of R.C. 4123.84 with regard to “flow-through” or residual medical conditions. The second issue is whether a self-insured employer who accepts a “flow-through” or residual condition as allowed, after the two-year limitations period set forth in R.C. 4123.84 has run, has conclusively granted that condition as part of the claim.

I

R.C. 1128.81 and Residual Conditions

R.C. 4123.841 provides:

*234“(A) In all cases of injury or death, claims for compensation or benefits…