Workers’ Compensation · Primary-source case analysis

Radilla: Medical Evidence Supported an Alternative Rating and Adding Impairments

By Aneeta Mishra and Timothy Chan

Published September 15, 2026

Raul Radilla received an award for neck, low-back, and left-shoulder injuries. The employer challenged both the QME’s alternative impairment analysis under Almaraz/Guzman and the decision to add impairments rather than use the Combined Values Chart.

An alternative rating needs reasoned medical evidence

A scheduled rating may be rebutted when another method within the four corners of the AMA Guides more accurately describes impairment. The physician must rely on an adequate history and examination and explain why the ordinary method misses the worker’s functional loss.

The QME tied the rating to functional effects

The Board found that the QME explained the impact of the conditions on activities of daily living and supplied a substantial-evidence basis for the selected alternative ratings rather than offering a conclusion without analysis.

The Combined Values Chart may be rebutted

Vigil ordinarily expects overlapping impairments to be combined. Radilla found substantial medical evidence supporting addition where the physician analyzed the affected activities and explained either an absence of overlap or an amplifying, synergistic effect.

The award remained in place

The Board denied reconsideration of the 96 percent permanent-partial-disability award and related life pension. The result turned on this developed medical record and does not make addition automatic whenever multiple body parts are involved.

Key takeaways

• Demand a reasoned explanation for every alternative AMA Guides rating.
• Map each impairment to identified activities of daily living.
• Analyze overlap and synergy before seeking addition rather than combination.
• Preserve the reports and deposition testimony supporting the rating.