All workers’ compensation practitioners are aware that the Pennsylvania Supreme Court had previously established a very complicated legal precedent in Jeanes Hospital v. WCAB, 872 A.2d 159 (Pa. 2005), under which Claimants were permitted to seek to amend the accepted description of injury, with the Jeanes Hospital Court allowing Claimants to file Review Petitions to “correct” Notices of Compensation Payable that did not contain a description of injury for which the Claimant sought amendment.

In Cinram Manufacturing v. WCAB, decided on July 21, 2009, the Supreme Court granted the employer’s Petition for Allowance of Appeal, in order to address the “correctness” of Jeanes’ Hospital directive, as it applied to corrective amendments of injuries described on Notices of Compensation Payable.