In City of Erie v. Workers' Compensation Appeal Board (Annunziata), 575 Pa. 594, 838 A.2d 598 (2003), our Supreme Court compared the Heart and Lung Act and the Workers' Compensation Act, particularly noting that the Workers' Compensation Act is similar to accident insurance and seeks to provide compensation commensurate with damage from accidental injury "as a fair exchange for relinquishing every other action against the employer." Id. at 601, 838 A.2d at 602. The Act is considered remedial legislation and is liberally construed in favor of the employee. Id. at 601-02, 838 A.2d at 602. However, under the Act, compensation for earnings loss is limited to 66 2/3% of an employee's average weekly wage, which limitation "serves to ameliorate the potential unfairness to employers." Id. at 602, 838 A.2d at 602-03. On the other hand, the Heart and Lung Act, which primarily covers police work, firefighting, and other jobs involving public safety, was created to "ensure that, if these employees were injured or otherwise disabled in the course of carrying out their hazardous duties, they would be guaranteed continued full income until their return to duty." Id. at 602, 838 A.2d at 603. Unlike the Workers' Compensation Act, enactment was motivated by the best interest of the public employer, i.e., the promise of full income to employees in a hazardous industry could serve to attract qualified individuals to the profession. Id. at 602-03, 838 A.2d at 603. Unlike the Workers' Compensation Act, the Heart and Lung Act is strictly construed. Id. at 603, 838 A.2d at 604. In addition, the Act contemplates the current receipt of workers' compensation: "Nothing in the Workers' Compensation Act eliminates the responsibility of an employer to pay workers' compensation to an injured employee who is receiving Heart and Lung benefits. . . . The employer's obligation to pay Heart and Lung benefits is concurrent with, not in lieu of, its obligation pursuant to the workers' compensation scheme." Id. at 605, 838 A.2d at 604-05. However, any workers' compensation received by an employee compensated under the Heart and Lung Act must be turned over to the employer. Section 1 of the Heart and Lung Act, 53 P.S. 637(a).