Jim Waldhauser of Cousineau. Waldhauser, & Kieselbach, P.A., has been selected by his peers as the 2019 Minnesota Lawyer of the Year - Workers' Compensation-Employers. This is a singular and well-deserved honor. 

Jim is a tremendous advocate who has contributed greatly to the profession.

For more information, please visit our website. 

Roller-Dick vs. CentraCare Health System, A17-1816 (Minn. August 8, 2018): 

ISSUE: ARISING OUT OF & IN THE COURSE OF

Procedural History of Case

In this case, Employee sustained an injury to her ankle after falling down a set of stairs located on the employer’s premises. The stairway had handrails on both sides as well as nonslip treads on the steps. However, Employee was not using the handrails because she was holding a personal plant from her desk as well as her handbag. She ended up falling on the stairs and injuring her ankle.

The matter proceeded to a Hearing. The sole issue before the compensation judge was whether her injury “arose out of” the employment. Relying onDykhoff v. Xcel Energy, 840 N.W.2d 821 (Minn. 2013) and Kirchner v. County of Anoka, 339 N.W.2d 908 (Minn. 1983), the compensation judge held that the injury did not arise out of employment because Employee failed to establish that the stairs were more hazardous than stairs she might encounter in everyday life or that her work duties in some way increased her risk of falling. The WCCA reversed and clarified that the issue is whether the stairs posed an “increased” as opposed to a “neutral” risk. The WCCA determined the stairs were inherently hazardous and not a neutral condition like the floor inDykhoff.

The Minnesota Supreme Court recently affirmed the WCCA’s decision.

Minnesota Supreme Court’s Analysis

For an injury to “arise out of employment,” there must be some “causal connection” between the injury and the employment. The Court noted that the case turns on whether the Employee faced a hazard that originated on the premises as a part of the working environment. In analyzing the Kubis and Hohlt decisions, the Court affirmed the core principles underlying the conclusion inDykhoff: “for an injury sustained on an employer’s premises to arise out of employment, the employee must have faced a hazard that originate on the premises as part of the working environment, thus supplying the requisite causal connection between the injury and employment.”

The Court compared this case to the Kirchner case, in which the Employee fell down stairs without using a handrail because persons ascending the staircase occupied the only side with the handrail. In this case, the Employee was not using the handrails as she was descending the stairs because she was carrying a plant as well as her handbag. The Court held that these circumstances created an increased risk that the Employee would fall and injure herself, thus satisfying the requisite causal connection between the workplace and her injury.

The Court goes on to explain that in workers’ compensation cases, it does not inquire whether the circumstances that led to an employee’s injury were attributable to either the employee or the employer. The Court notes that the dissent’s opinion that the fall is not compensable due to the Employee’s decision to not take advantage of the handrails returns the case to the negligence standard that the Workers’ Compensation Act expressly rejects. In a footnote, the majority opinion expressly states “we do not hold… that stairs themselves are workplace hazards exposing employees to an increased risk of injury. Rather, we conclude that the now-undisputed factual circumstances surrounding Roller-Dick’s injury… amount to an increased risk as a matter of law.”

Dissent

Justice Gildea, in the dissenting opinion, states that there is no dispute that the Employee satisfies the “in the course of” requirement of the statute, but that because the Employee did not establish a causal connection between her injury and her employment, she does not meet the “arising out of” element. The dissent points out that by failing to require a connection to the Employee’s actual job duties, the majority opinion effectively does away with the “arising out of” element of the statute. The dissent felt that carrying a personal plant and not holding the handrail was not sufficient for an increased risk connected to the employment.

Why this case matters

Failure to use handrails on employer-maintained staircases can lead to compensable injuries, even if the employee’s reason for not holding the handrail is purely personal in nature (i.e. carrying personal items). Notably however, this decision explicitly declined to provide a bright-line rule that stairs are inherently hazardous. There likely will be more cases to come addressing this issue of employer staircases.

For the full decision, click the link below:

https://mn.gov/law-library-stat/archive/supct/2018/OPA171816-080818.pdf

Summary completed by Bryan Wachter and Parker Olson, CWK Associate Attorneys 

Hufnagel v. Deer River Health Care Center, A17-2064 (Minn. July 18, 2018)

In this case, Employee sustained an admitted injury to her low back in 2009 while working for Deer River. Deer River then became Essentia Health-Deer River and changed its insurer in 2013. Employee continued to work there, and sustained aggravations to her low back in 2014 and 2015. Employee then filed a Claim Petition; however it was solely against the 2009 Deer River injury. Attorney for Deer River asked Employee’s attorney to join the 2014 and 2015 Essentia Health injuries to the matter, but he refused. Subsequently, Deer River filed a Motion for Joinder to add Essentia Health to the case. This was granted. At the Hearing, Employee’s attorney indicated that he did not believe there were any injuries in 2014 or 2015, which was contrary to the opinion of an Independent Medical Examiner. Judge Kohl instead found that there were injuries in 2014 and 2015 and ordered Essentia Health to make payment of wage and medical benefits. There were no benefits awarded against the 2009 injury and Deer River.

Employee subsequently claimed attorney fees under Roraff/Irwin and Minn. Stat. §176.191 in the amount of $31,120.00. In support of the claim for .191 fees, Employee asserted that the primary dispute in the case was between the two insurers, even though both insurers had denied primary liability. At the hearing for attorney fees, Employee’s attorney was found to be entitled to $8,000 inRoraff/Irwin fees. The compensation judge concluded that Employee was not entitled to recover attorney fees for the time her attorney spent in re-establishing the 2009 injury. Additionally, it was noted that since Deer River was actually the entity to join Essentia Health, which ultimately gave rise to compensation for Employee, that Employee’s attorney fee claim should be reduced. The compensation judge denied any additional fees under Minn. Stat. §176.191, as he found that the primary dispute was not between the insurers, but rather between the employee and the insurer(s).

The WCCA reversed this decision, holding that the compensation judge failed to fully consider the extent to which each employer sought to shift liability to the other employer and that it was error to deny the motion for fees under Minn. Stat. §176.191, subd. 1. They also held that Employee’s attorney was entitled to recover additional attorney fees underRoraff/Irwin.

Essentia Health appealed the decision to the Minnesota Supreme Court. The Minnesota Supreme Court affirmed the WCCA. The Court addressed two issues: (1) whether the compensation judge erred in concluding that there was no dispute between the two employers that would entitle her to fees under Minn. Stat. §176.191, and (2) whether the Employee is entitled to recover attorney fees for the time spent in establishing the 2009 injury.

With regard to the .191 fees, the Court concluded that it was error for the compensation judge to determine the dispute in this case was not primarily between the insurers. The Court held that whether the 2009 injury was a substantial contributing factor in the Employee’s ongoing physical condition was, at its heart, a dispute about which employer was liable for the benefits the Employee would be entitled for 2014 and 2015 injuries. The efforts by each employer to shift responsibility to the other employer greatly increased the burden on the Employee’s counsel to provide effective representation, and therefore the Court held she was entitled to receive reasonable attorney fees under Minn. Stat. §176.191, subd. 1. Even though the Employee had not been guaranteed any compensation for herself going into the Hearing as both insurers denied liability, the Court still found that the primary dispute was between the insures.

With regard to the issue of Roraff/Irwin fees, the Court held that although the case before the compensation judge was not itself about an award of benefits specific to the 2009 injury, some amount of time and effort was still necessary to adequately prepare for and respond to the argument the employers raised regarding the 2009 injury and its relationship to the 2014 and 2015 injuries. The Court discussed its expectation that attorneys thoroughly prepare to represent their clients and that an award of reasonable fees should be adequate to compensate an employee’s attorney for the value of representation provided, including for the time reasonably necessary to thoroughly prepare.

One key takeaway from this decision is that the standard for .191 attorney fees is not a bright-line rule. In a situation where there are two insurers (who even both deny primary liability), Employee’s attorney may be found to be entitled to fees under Minn. Stat. 176.191 if there is enough “finger pointing” between the two insurers. Such situations require a full case-by-case analysis of all the facts to make a determination.

For the full decision, click the link below.

https://mn.gov/workcomp-stat/sup/Hufnagel-sup%2018.html

Summary completed by Bryan Wachter, CWK Law Associate Attorney 

Samuel Kamenette drove over-the-road trucks for Sangillo & Sons.  He was injured on October 9, 2015  in the State of Wyoming. He was driving a load from California to New Jersey.  He slept the night before in his truck, and in the morning he drove for an hour to a Flying J, part of a Pilot Flying J nationwide chain.  He purchased over 50 gallons of fuel, parked the truck, went into the Flying J, and he took a shower.  He then dressed in the shower area preparing to renew his drive.  He sat on a bench to put on his boots, but the bench collapsed causing injuries.  He alerted his employer of the injury and then drove to a clinic for treatment, obtaining pain killers, before driving back to New Jersey.

Kamenette brought a workers’ compensation claim and also settled with Pilot Flying J for $40,000 in a third party action.  He filed a motion for medical and temporary disability benefits in the workers’ compensation case, and the Judge of Compensation ruled in his favor, finding that the accident arose from the employment.  Sangillo and Sons appealed.

At trial Kamenette testified that he needed to take the shower partly because it is an appearance issue.  He represents his company.  He also said that a shower keeps him more alert. The Appellate Division rejected both rationales.  It said that Kamenetti did not testify that he had been drowsy and said that since petitioner had no deliveries to make, the appearance argument also failed.   The Appellate Division felt that his showering was therefore “indistinguishable from the showering of countless on-premises employees in their homes every day before going to work.”   The Court said:

It would not be consonant with the language or intent of the 1979 amendments to extend workers’ compensation to cover employees engaging in pre-work activities that will make them more refreshed, efficient, alert, fragrant, or attractive during the work day, such as bathing, eating breakfast, drinking coffee, exercising, or dressing.  Treating these pre-work activities as covered would contravene the requirement that the employee “engaged in the direct performance of duties assigned or directed by the employer.”

The Appellate Division further commented as follows: “Thus, had Kamenetti stayed in a motel or truck stop with a shower, showered there, and injured himself while dressing, he would be equally ineligible for compensation as an on-premises employee who slept, showered, and dressed at home.  However, he chose to stay at a ‘mom and pop’ truck stop that had no showers, and therefore had to go elsewhere to shower. The choice does not change the result.”

This statement in the preceding paragraph seems to run counter to Johnson-Tucker v. Plainfield Board of Education, No. A-5078-06T3 (App. Div. July 1, 2008).  There a petitioner attended a Board approved seminar in Georgia.  She was unable to get a room in the hotel where the seminar was located.  Before the seminar began, she went to breakfast in her hotel, and the chair she was sitting in collapsed causing injury.  The Appellate Division held that this injury was in fact work related, embracing the theory that injuries in the hotel would be compensable because getting a meal was necessary, even if the petitioner was not at the hotel where the seminar took place yet.

The Appellate Division also rejected the argument that Mr. Kamenetti’s injury was a minor deviation from employment.  The Court distinguished one case involving an off-premises compensable coffee break. In that case the injured employee was a foreman who went to the union hall to discuss a new job with a union instructor.  Since the instructor was busy, the foreman took his break and drove five miles to get a cup of coffee as there was no coffee in the union hall.  He was injured in a car accident on the way.  The Appellate Division found that case compensable on the theory that off-premises employees are entitled to the same coffee breaks as on-premises employees, but it felt it had no application to this set of facts.

In the end, the Appellate Division found that the petitioner’s shower was a “personal activity,” not a duty.  An attorney for COSH filed an amicus curiae brief, arguing that the petitioner’s shower was covered under the “Personal Comfort Doctrine,” which New Jersey recognizes.  Certain activities like going to a restroom, going on a coffee break or smoking a cigarette have historically been accepted in most states under the Comfort Doctrine.  Counsel argued that the need to take a shower for someone who drives across the country fits squarely within this doctrine.  The Appellate Division would not entertain this interesting argument because the issue had not been raised at the Division of Workers’ Compensation level.

This case is not reported but it underscores how challenging it is to differentiate what is or is not a minor deviation.  The five-mile drive for a cup of coffee was considered a minor deviation, but the Appellate Division in this case felt that the shower was purely personal and therefore a major deviation.  The case can be found at Kamenetti v. Sangillo & Sons, A-0394-16T3 (App. Div. August 8, 2018).

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John H. Geaney, Esq., is an Executive Committee Member and a Shareholder in Capehart Scatchard's Workers’ Compensation Group.  Mr. Geaney concentrates his practice in the representation of employers, self-insured companies, third-party administrators, and insurance carriers in workers’ compensation, the Americans with Disabilities Act and Family and Medical Leave Act. Should you have any questions or would like more information, please contact Mr. Geaney at 856.914.2063 or by e‑mail at jgeaney@capehart.com. 

George Washington, an employee of Runnells Center for Rehabilitation and Healthcare, left work on March 5, 2015 and drove his car to pick up lunch at a nearby restaurant.  Returning from lunch, his car struck a guardrail on a snow-covered access driveway owned by Runnells.  He completed an accident report at the scene, exited his vehicle, then slipped and fell, fracturing his ankle.

In April 2016, Washington sued Runnells, his employer, seeking compensatory damages.  Defendant Runnells surprisingly failed to argue that workers’ compensation was plaintiff’s exclusive remedy.  One cannot sue one’s employer in civil court except for rare exceptions.  Eventually Runnells amended its position in the case to argue that plaintiff could not sue the company in civil court, and the amendment was allowed.  That set the stage for an interesting decision.  Was Mr. Washington at work when he slipped and fell on an access road coming back from lunch?

The Superior Court held that plaintiff could not bring a civil suit against Runnells.  It did not matter that plaintiff was returning from a lunch break.  His car had reached the premises owned or controlled by his employer and he was technically in the course of employment when he was injured.  Therefore his sole remedy was workers’ compensation benefits, something Washington did not desire.

Washington relied on Acikgoz v. N.J. Tpk. Auth., 398 N.J. Super. 79 (App. Div. 2008).  He argued that his case was similar to this 2008 case.  In that case two vehicles collided on an access road owned by the New Jersey Turnpike Authority, and a civil case was allowed.  Both drivers worked for the Turnpike Authority. Acikgoz had completed his shift and was heading home.  Lowden, the other driver, was merely driving to work to pick up his paycheck.

The Court in Acikgoz allowed the civil law suit stemming because it held that Lowden was not in the course of his employment, as he was just picking up a paycheck. He was not there to work.  Further, the access road was open to the public.  The Court found that Lowden used the access road for “convenience” rather than for the benefit of his employer.

The Appellate Division concluded that Washington’s case was not the same as Acikgozat all. The Appellate Court felt that Washington’s civil case was barred because plaintiff was technically at work when he was injured on the employer’s premises.  The court noted that the road he was on was not used by the public.  The Court also held that the civil case should be dismissed without prejudice pending a decision in the Division of Workers’ Compensation on the issue of compensability.  It is noteworthy that the Appellate Division in this case deferred to the Division of Workers’ Compensation for the final say on the application of the premises rule, predicting that the Division of Workers’ Compensation would be in agreement.  That has not been the trend in recent cases where the Superior Court has been faced with workers’ compensation compensability decisions, making their own final determination.

This case can be found at Washington v. Runnells Operating, LLC, A-3996-16T2 (App. Div. July 25, 2018).  It illustrates an important point in workers’ compensation.  The premises rule is a strict rule.  When one is on the premises to work, workers’ compensation laws apply.  It does not matter that one may be returning from lunch or returning from an off-premises shopping errand: the mere presence on the premises to renew work is enough to bring the worker within the protection of workers’ compensation.  In this case Washington fought hard to be outside workers’ compensation because the potential for damages is often far greater in the civil courts than in workers’ compensation.

Thanks to our friend, Ron Siegel, Esq. for bringing this interesting case to our attention.

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John H. Geaney, Esq., is an Executive Committee Member and a Shareholder in Capehart Scatchard's Workers’ Compensation Group.  Mr. Geaney concentrates his practice in the representation of employers, self-insured companies, third-party administrators, and insurance carriers in workers’ compensation, the Americans with Disabilities Act and Family and Medical Leave Act. Should you have any questions or would like more information, please contact Mr. Geaney at 856.914.2063 or by e‑mail at jgeaney@capehart.com. 

  West Virginia Supreme Court Impeachments - Latest Developments and Update

August 14, 2018

 August 14, 2018 update

 There have been significant developments in recent days regarding the Articles of Impeachment brought against the four remaining Justices of the Supreme Court of Appeals of West Virginia.   

 On August 9, 2018, Chief Justice Workman issued an Administrative Order temporarily appointing the Honorable Paul T. Ferrell, Judge of the Sixth Judicial Circuit, to serve on the Supreme Court during Justice Loughry's suspension. Judge Ferrell's assignment commenced immediately and will continue until the Chief Justice determines such assistance is no longer necessary. Justice Workman's Order further notes that should the Articles of Impeachment brought forth by the House Judiciary Committee proceed to the Senate for trial, Judge Ferrell will serve at the Acting Chief Justice for any impeachment proceedings. 

 On Monday, August 13, the House of Delegates convened for a 14-hour floor session and voted to adopt eleven separate Articles of Impeachment put forth by the Judiciary Committee. 

 Following the votes in the House of Delegates, on August 14, 2018, Justice Robin Davis announced her immediate retirement from the Supreme Court. Justice Davis's retirement means that the unexpired six years of her term (until 2024) will also be on the ballot in the November 2018 general election. As previously reported, Justice Ketchum's seat will also be on the ballot in the November 2018 general election. Prior to that election, Justice Davis's position on the Supreme Court could be filled by an appointee of the Governor of West Virginia, or Chief Justice Workman could fill the seat through use of temporary appointment powers.

The remaining articles of impeachment approved by the House of Delegates against Justices Loughry, Walker, and Workman will go to the State Senate for trial. At this time, there is no timetable for any proceedings before the Senate, however, impeachment of any Justice would require a 2/3 vote in the Senate for conviction and potential removal from office. 

 The Supreme Court's Fall Term is scheduled to begin on September 5, 2018.

 If you have specific questions, reach out either to your Spilman contact, or Andrew P. Arbogast (Chair, Litigation Department), or Don C. A. Parker (Chair, Appellate Group) for more information. 

New Jersey has a sensible provision that protects employees of subcontractors who are injured on construction jobs.  If an employee of a subcontractor is injured on a job, and the subcontractor has no workers’ compensation insurance, the injured employee becomes covered by the general contractor’s workers’ compensation policy.  But what if the injured employee instead decides to file a civil suit against the general contractor for negligence?  Does the general contractor’s liability insurance policy cover the civil suit? Can the injured employee sue the general contractor and obtain workers’ compensation from the general contractor?

These questions were answered in DaSilva v. JDDM Enterprises, LLC, David Cohen, t/a JDDM Custom Construction, A-3302-16T2 (July 27, 2018).  The case involved an injury to Mr. DaSilva.  He was working for Hand Brothers on a construction job.  Hand Brothers was a subcontractor of JDDM, the general contractor.  DaSilva fell one story through a cut-out stairwell on the job and suffered injuries.  Hand Brothers had allegedly presented a fake certificate of insurance to JDDM and actually had no compensation coverage.

DaSilva sued JDDM and its principal, David Cohen, seeking damages in a civil action.  JDDM referred the suit to Utica Insurance, its liability carrier.  Utica declined coverage because its policy excluded workers’ compensation injuries.  JDDM and Cohen then filed a third-party declaratory judgment action against Utica, seeking an injunction to compel Utica to defend NJJD and Cohen in the civil action.  Utica then moved for summary judgement arguing that the declaratory judgment suit must be dismissed as Mr. DaSilva’s injuries arose from work. Utica further contended that DaSilva was covered by JDDM under N.J.S.A. 34:15-79 because JDDM was the general contractor.

The trial judge granted summary judgment in favor of Utica.  JDDM and Cohen settled the civil claim with DaSilva and then appealed the decision to let Utica out of the case.  The Appellate Division reviewed the language contained in Section 79.  “Under this provision, a contractor who retains a subcontractor becomes liable for workers’ compensation benefits owed to the subcontractor’s employees if the subcontractor does not provide workers’ compensation insurance.”

The Appellate Division also took note of the fact that JDDM’s workers’ compensation carrier in fact admitted liability under Section 79 to DaSilva. The Appellate Division ruled that Utica’s policy excluding coverage for benefits that are provided or are required to be provided under workers’ compensation was valid.  Since JDDM was required to provide workers’ compensation coverage under Section 79, Utica was well within its rights to deny coverage on the civil suit.

What about the right of DaSilva to sue the general contractor while at the same time asserting coverage for workers’ compensation against the general contractor under Section 79?  Does the exclusive remedy provision apply barring his civil law suit?  The Appellate Division commented as follows: “Because general contractors are not part of an employment contract between a subcontractor and its employees, they are ‘not required to provide workers’ compensation coverage, and do not enjoy the immediate employer’s immunity from tort liability,” citing to Eger v. E. I. du Pont de Nemours Co., 110 N.J. 133, 137 (1988).

So the Court was saying that DaSilva’s civil law suit against the general contractor was not barred under the exclusive remedy provision. That may seem unfair to the general contractor.  However, Section 79 does allow the general contractor to full reimbursement from the subcontractor which failed to carry insurance.  In addition, there would be subrogation issues here under Section 40.  DaSilva had a double recovery here.  He settled his civil suit against the general contractor and obtained workers’ compensation benefits from the general contractor by virtue of Section 79.  Therefore, the worker’s compensation carrier would be entitled to assert subrogation rights and thereby reduce its obligation to DaSilva.

Thanks to our friend Ron Siegel, Esq. for bringing this case to our attention.

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John H. Geaney, Esq., is an Executive Committee Member and a Shareholder in Capehart Scatchard's Workers’ Compensation Group.  Mr. Geaney concentrates his practice in the representation of employers, self-insured companies, third-party administrators, and insurance carriers in workers’ compensation, the Americans with Disabilities Act and Family and Medical Leave Act. Should you have any questions or would like more information, please contact Mr. Geaney at 856.914.2063 or by e‑mail at jgeaney@capehart.com. 

West Virginia Supreme Court Impeachments - Latest Developments and Update

August 9, 2018

On August 7, 2018, the Judiciary Committee of the West Virginia House of Delegates voted to move forward with 12 articles of impeachment against four sitting justices of the Supreme Court of Appeals of West Virginia stemming from alleged overcompensation of senior status judges, improper use of state property, and inappropriate use of state funds. Articles of impeachment were brought against Justices Allen Loughry, Margaret Workman, Robin Davis, and Beth Walker. No articles were issued against Justice Menis Ketchum, who previously resigned his position on the Court. Justice Ketchum's seat will be on the ballot in the November 2018 general election. Prior to that election, his position on the Supreme Court could be filled by an appointee of the Governor of West Virginia.

The full House of Delegates is scheduled to convene on Monday, August 13 to consider the articles of impeachment put forth by the Judiciary Committee against the four remaining justices. Any articles of impeachment approved by the House of Delegates will go to the state Senate for trial. Impeachment of any justice would require a 2/3 vote in the Senate.

This is an historic event in West Virginia politics and for the judicial branch, for which the implications are unprecedented. Many questions remain regarding how cases on appeal before the Supreme Court will be addressed. The Supreme Court is currently in recess, with case conferences for the coming term scheduled to begin on August 28, 2018. The Court is scheduled to hear the first oral arguments of the new term on September 5, 2018.

This situation is fluid with many variables in play. Spilman is monitoring the situation on a daily basis, and will keep you updated with any breaking news. If you have specific questions, reach out either to your Spilman contact, or Andrew P. Arbogast (Chair, Litigation Department) aarbogast@spilmanlaw.com, or Don C. A. Parker (Chair, Appellate Group) dparker@spilmanlaw.com for more information.

Legislative Update by Attorney Alison Stewart       

WCES - Workers' Compensation Electronic System         

A new electronic filing system is tentatively scheduled to be implemented beginning in December of 2018. The new system will be known as Workers’ Compensation Electronic System, or WCES (pronounced “wick-ess”). Training will be provided by the Iowa Division of Workers’ Compensation for attorneys and other stakeholders who will be required to use the system. It is the intention of the Division that the system will provide for electronic filing of all pleadings and documents with the Division. The new system will also provide for more efficient scheduling of hearings, comprehensive case management, and greatly improved EDI transactions. The proposed administrative rules relating to the implementation of this system were recently sent out for comment and we are now waiting for them to be adopted. These rules will instruct parties how to appropriately navigate the new system.

CourtCall 

The Division of Workers’ Compensation is now providing a system to conduct hearings by phone or video through a system called CourtCall. This system allows attorneys and parties to avoid travel time and the cost of commuting to a hearing location. The system is currently available at the Des Moines hearing venue for any hearing the parties and the hearing deputy agree to. It may also be available for road venues with advanced arrangements. There are some expenses associated with use of this program. The cost is $45 for the first 45 minutes and $12.50 for each 15 minute increment thereafter. This could be an excellent tool for remote employer witnesses, for example.

More information on these systems can be found at:  https://www.iowaworkcomp.gov/news-and-updates