Applicant Gloria Gonzalez, a CNA, suffered an admitted left shoulder injury on October 7, 2022 while lifting a patient. The company clinic imposed a five-pound lifting restriction (later eased to 20 pounds and released to full duty on June 14, 2023). On November 1, 2022, her supervisor changed her status from full-time to PRN (as-needed), which the WCJ found was uninformed and therefore involuntary. The WCJ awarded temporary disability for November 1, 2022 through June 14, 2023, and defendant petitioned for reconsideration. The Board denied reconsideration, holding that the employer failed to meet its burden of establishing a bona fide offer of modified or alternative work, which is required to be relieved of temporary disability liability regardless of whether the change to PRN status was voluntary.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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