Vanegas Gerena, Edwar

Applicant, a tree trimmer, suffered a serious left hand injury on April 29, 2021 when a powered chainsaw fell approximately 10 feet onto his hand, leading to multiple surgeries, development of CRPS in the left upper extremity, compensatory right shoulder/upper extremity pain, and a psychiatric injury (Major Depressive Disorder). The WCJ found permanent total disability with no apportionment, relying on QME Dr. Rakkar (orthopedic/pain) who rated the left UE CRPS under Class 4 (45% WPI plus 3% pain) and right shoulder at 4% WPI, and psychiatric QME Dr. Alvarellos (30% WPI/GAF 50). Both QMEs opined the orthopedic and psychiatric impairments should be added rather than combined under Kite/Vigil because the ADL impacts did not overlap. Defendant challenged the PTD rating, the substantiality of Dr. Rakkar's Class 4 finding, and argued no evidence of lost earning capacity. The Board adopted the WCJ's Report and denied reconsideration, finding the QME opinions constituted substantial medical evidence and that Vigil does not require vocational evidence of lost earning capacity.