How has the statute of limitations for vocational rehabilitation been interpreted in the context of rehabilitation?
California, United States of America
The following excerpt is from Sacramento Cnty. office of Ed. v. Workers' Com. Appeals Bd., 82 Cal.App.4th 107, 97 Cal.Rptr.2d 699 (Cal. App. 2000):
In Youngblood v. Workers' Comp. Appeals Bd. (1989) 216 Cal.App.3d 764 (Youngblood), the WCAB attempted to reconcile these statutes of limitations in the context of rehabilitation services. In Youngblood, an employee injured in 1978 obtained a permanent disability award, but the WCAB in 1982 determined the employee was not eligible for rehabilitation benefits. The employee filed a petition to reopen for the purpose of finding new and further permanent disability. The employee did not allege the need for vocational rehabilitation as a ground for reopening. (Id. at pp. 767-768.)
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