In Montana, All Employments Used To Determine AWW / TTD / PPD
March 29, 2022 – Michael Marsh
Excellent summary review of the recent Montana State Fund case entitled Barnhart v. Montana State Fund, 2022 MTWCC 1. MT requires that all wages from all employments be used to calculate Average Weekly Wage (AWW), which determine the TTD AND PPD rates, not just the wages from the at risk employer/insurer.
Access the full case write up @ https://www.leagle.com/decision/inmtco20220211296
Takeaway: A critical determination that must be made on any accepted workers' compensation claim in Montana for Average Weekly Wage MUST INCLUDE the income received by the injured/recovering worker for the 4 pay periods prior to the injury date. This calculation applies to the following determination of TTD and PPD rates.