Land O'Lakes, Inc. v. WCAB (Todd)

In Land O'Lakes, Inc. v. Workers' Compensation Appeal Board (Todd), 942 A.2d 933 (Pa. Cmwlth.) the Court stated, "Employer's remedy under Section 306(f.1)(8) is not monetary; rather, it is the ability to force a claimant to choose between the recommended medical treatment and forgoing compensation because medical treatment was refused." Land O'Lakes, 942 A.2d at 937. There is nothing in Section 306(f.1)(8) which leads to the conclusion that an employer is entitled to a credit against a claimant's future earnings. Section 306(f.1)(8) is analogous to a suspension or termination petition in which the employer has no right to recovery from a claimant due to the latter's unjust enrichment.