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 · Updated October 21, 2026

Decision: Radilla v. Caravan Foods II, Inc., No. ADJ12660780 (WCAB Aug. 31, 2026).

This August 31, 2026 WCAB panel decision evaluates the QME’s alternative impairment analysis and the combined-rating record. 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. These were separate questions: Did the selected impairment ratings accurately describe the worker’s limitations, and did the evidence justify addition instead of the usual combination? A report supporting one step does not automatically establish the other.

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 panel required medical reasoning within the AMA Guides, not an unrestricted choice of a larger number. Radilla, slip opinion, pages 4–5.

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. Its decision rested on reports and deposition testimony, not merely the presence of several diagnoses. The adopted judge’s report described the standard and alternative ratings and why the doctor preferred the alternatives. Radilla, slip opinion, pages 5, 15–17.

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 effect, meaning that the impairments made the same activity harder together. The adopted report gave a concrete example: Lifting an object from the floor required back movement and shoulder reaching and strength at the same time. The doctor explained how the limitations compounded one another. Radilla, slip opinion, pages 6, 14, 17.

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. The 96 percent was the permanent-disability result, not a raw sum of the doctor’s whole-person impairment figures. In this award, the rated components were 51, 16 and 29 percent, which the judge added to reach 96. Do not transfer those numbers or the method to a different worker without the supporting medical and rating analysis. Radilla, slip opinion, pages 1, 18.

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.