The Kansas Court of Appeals recently ruled in a significant workers' compensation case involving Betzaida Suarez-Cirino and her employer, Menard, Inc. The court's decision impacts how future medical benefits are handled under the Kansas Workers Compensation Act. This ruling is crucial for workers seeking ongoing medical care after workplace injuries.
In this case, Suarez-Cirino, who injured her shoulder while working as a cashier, had her future medical benefits terminated by the Workers Compensation Board after her employer claimed she no longer needed medical care. The court's decision, filed on October 23, 2026, reverses that termination, allowing Suarez-Cirino to continue receiving benefits.
Background
Betzaida Suarez-Cirino injured her left shoulder in February 2014 while lifting heavy items at Menards. Following the injury, she received treatment, including surgery for a torn rotator cuff. After returning to work, she sustained a right shoulder injury, which led to further complications. Menards initially compensated her for the left shoulder injury but later denied benefits for the right shoulder, claiming it was due to preexisting conditions.
In 2019, an administrative law judge (ALJ) determined that Suarez-Cirino's right shoulder injury was compensable and authorized future medical treatment. However, after a period without treatment, Menards sought to terminate her future medical benefits, claiming that she had not received authorized medical treatment for over two years. The ALJ agreed, leading to an appeal by Suarez-Cirino.
The Ruling
The Kansas Court of Appeals ruled that the Workers Compensation Board misinterpreted K.S.A. 2015 Supp. 44-510k(a)(3), which governs the termination of future medical benefits. The court stated, "the presumption would not apply in her case until, at the earliest, two years after the date of that award." This means that the two-year period for determining whether benefits can be terminated begins from the date benefits are awarded, not from the last time medical treatment was received.
The court found that the Board had unduly shortened the deadline for invoking the statutory presumption, which led to an incorrect termination of benefits. The ruling emphasized that the presumption could be overcome by competent medical evidence, allowing Suarez-Cirino to present her case for continued benefits.
Impact
This ruling has significant implications for workers' compensation cases in Kansas. It clarifies how the statutory presumption regarding future medical benefits should be applied, ensuring that claimants are not unfairly penalized for gaps in treatment that occur after an award of benefits. The decision reinforces the importance of allowing injured workers to seek necessary medical care without the fear of losing their benefits prematurely.
Workers in similar situations can now feel more secure in their rights to future medical care, as the court's interpretation ensures that the timeline for assessing the need for continued benefits is fair and reasonable. This ruling may also influence how employers approach the termination of medical benefits in future cases.
What's Next
Following this ruling, the case is sent back to the Workers Compensation Board for reconsideration of whether Suarez-Cirino's future medical benefits should be terminated without applying the erroneous presumption. Details were not available in the court filing regarding potential appeals or related cases.