Saunders House v. WCAB (Russell)

In Saunders House v. Workmen's Compensation Appeal Board (Russell), 156 Pa. Commw. 505, 628 A.2d 488 (Pa. Cmwlth. 1993), an employer sought to modify benefits based on a claimant's refusal to accept medically approved employment. The Court held that the claimant's refusal constituted grounds to grant a modification petition. Employer argues that because the job referrals at issue were based on an IME that was more than a year old, Saunders House directly refutes the premise that an IME expires after six months. However, the issue in Saunders House was whether the claimant received notice that she was medically cleared to return to work, not the continued viability of an IME after six months.