Fred Meyer, Inc. v. Bundy

*47EDMONDS, J.

Employer seeks review of a Workers’ Compensation Board (Board) order ruling that claimant is entitled to temporary disability benefits as of May 11, 1993. We review for errors of law, ORS 656.298(7) and ORS 183.482(8), and reverse.

Claimant has a compensable right wrist condition. The claim was initially closed in 1992. In May 1993, claimant filed an aggravation claim and a request for surgery, which employer denied. The denial was set aside by the Hearings Division, and employer appealed to the Board, which affirmed. That order has become final. In May 1995, claimant requested temporary disability benefits. On May 24, 1995, claimant’s attending physician authorized the payment of temporary partial disability (TPD) compensation from November 1992 through April 1995. Employer acknowledged receipt of the authorization, but paid no TPD. In August 1995, employer issued a notice of closure that was subsequently affirmed on reconsideration. The order awarded TPD from April 25,1995, to August 3,1995, the date that claimant had become medically stationary. Claimant requested a hearing on the order on reconsideration, arguing that he was entitled to TPD beginning on May 11, 1993, the date the aggravation claim was made. The Board agreed with claimant’s argument, and employer seeks review.

Employer argues that:

“The 1995 Legislature determined, by enacting ORS 656.262(4)(g),[1] that an attending physician may not retroactively establish a claimant’s entitlement to temporary disability benefits for any period unless he has authorized the disability within 14 days of such period. The Board majority erred in concluding that this provision applies *48only to an employer’s procedural obligation to pay temporary disability while a claim is open and does not also govern the claimant’s ability to establish substantive entitlement to such benefits upon claim closure.” (Internal footnote omitted.)

In response to employer’s argument, claimant asserts:

“The changes made to Chapter 656 by Oregon Law 1995, Chapter 332 should not be retroactively applied to this claim. However, if the provisions of Oregon Laws 1995, Chapter 332 are applicable, the 1995 revisions to ORS 656.262 did not eliminate the distinction between procedural and substantive temporary disability. Even if the amendments did abolish the distinction, the limitation on retroactive authorization does not apply to the present case where the claimant had been seen by the attending physician for several years. The legislature intended to prohibit retroactive authorization for cases involving initial claims. In the present case, the worker had seen his attending physician to obtain ongoing treatment for the same condition for a period of five years.”

1. The meaning of ORS 656.262(4)(g) is the focal point of the parties’ arguments. It provides:

“Temporary disability compensation is not due and payable pursuant to ORS 656.268 after the worker’s attending physician ceases to authorize temporary disability or for any period of time not authorized by the attending physician. No authorization of temporary disability compensation by the attending physician under ORS 656.268 shall be effective to retroactively authorize the payment of temporary disability more than 14 days prior to its issuance.”

ORS 656.262(4)(g) was enacted by the legislature in 1995. Senate Bill 369; Or Laws 1995, ch 332. ORS 656.262(4)(g) was enacted while this claim was in litigation. Therefore, the amendment applies. Jensen v. Conagra, Inc., 152 Or App 449, 954 P2d 822 (1998);2 Volk v. America West *49Airlines, 135 Or App 565, 899 P2d 746 (1995), rev den 322 Or 645 (1996).

The remaining issue in this case is whether ORS 656.262(4)(g) applies to only procedural obligations to pay temporary disability while a claim is open, or whether it also applies to the substantive entitlement to benefits at claim closure. The Board ruled that ORS 656.262(4)(g) is only an additional requirement for the authorization of procedural temporary disability compensation during an open claim. It reasoned that, because the terms in the statute are in the present tense and thereby address the contemporaneous payment of compensation while the claim is in open status, it follows that the statute does not apply to awards of temporary disability made at the time of closure. The Board noted that a claimant’s entitlement to temporary disability benefits under ORS 656.210 and ORS 656.212 was not amended in 1995 in any way that was material to the meaning of ORS 656.262(4)(g) and that neither ORS 656.210 nor ORS 656.212 contains any language that limits a worker’s substantive entitlement to temporary disability to only those periods for which there has been contemporaneous authorization by the attending physician. Based on that reasoning, the Board concluded that ORS 656.262(4)(g)’s restriction on the authorization of temporary disability benefits was inapplicable to claimant’s claim for substantive temporary disability benefits.

The pertinent statutes are reasonably susceptible to the construction given to them by the Board. However, that conclusion does not end the inquiry. In interpreting a statute, our task is to discern the intent of the legislature. ORS 174.020. The text of the statutory provision itself is the starting point for interpretation because it is the best evidence of the legislature’s intent. We also consider the context of the statutory provision at issue, which includes other provisions of the same statute and other related statutes as well as rules of construction of the statutory text that bear directly on how to read the text. If the legislature’s intent is clear from such an inquiry, there is no need to go further. It is with those rules in mind that we examine ORS 656.262(4)(g) to determine whether the Board’s interpretation is the only reasonable construction of the meaning of ORS 656.262(4)(g).

*50On its face, ORS 656.262(4)(g) is not limited to benefits that are due and payable during the time that the claim is open. The first sentence in the statute tells the reader when temporary disability compensation is not due and payable; the second sentence in the statute restricts the retroactive authorization of temporary disability compensation to a time period of not more than 14 days. The fact that the verbs in the statute are in the present tense does not negate the possibility that the statute also applies to awards of time loss3 made at claim closure. Whether time loss is awarded while a claim is open or at closure will always be an act that occurs contemporaneously to the overall processing of the claim. Moreover, the reference to ORS 656.268 in both sentences is a reference to a statute that addresses the process of claim closure. Finally, the fact that ORS 652.210 and ORS 656.212, statutes regarding the substantive entitlement to temporary disability, remain unchanged is not determinative of the issue. The legislature could well have intended that the requirements in those statutes remain the same, while intending to superimpose upon them a limitation on the retroactive award of such benefits. We conclude, based on the above examination, that the intent of the legislature is not clear from the text and the context of ORS 656.262(4)(g).4 In light of its language, the legislature could have intended that the 14-day restriction on TPD apply to both procedural and substantive time loss.

As a result of the purpose of the legislature not being clearly discernable from the text and context of ORS 656.'262(4)(g), we consider the legislative history underlying the statute. Our review of the legislative history discloses that the changes in ORS 656.268 were “intended to preclude a closure order from making a substantive award of time-loss benefits for any period of time during which procedurally the time-loss benefits were lawfully suspended or withheld or *51terminated.” Tape recording, Joint Meeting of Senate Committee on Labor and Government Operations and House Committee on Labor, February 1,1995, Tape 19A.

In addition, the following exchange took place at a legislative committee meeting on Senate Bill 369:

“[Representative Kevin Mannix addressing Senator Randy Leonard]: You were surprised, and I think even shocked, that it could be possible under the act that a physician could do retroactive time loss. Senator, it happens. And, we’ve been required to respond to it. And, we’ve been penalized for not paying it — periods of time during which the time loss might have been monitored, the worker’s medical condition might have been reported on, but it wasn’t. We end up getting a retroactive authorization for — I have seen two years of time loss, I have seen more.
“[Senator]: Retroactive?
“[Jerry Keene]: Doctor says, I’m going back two years to authorize time loss even though I haven’t seen you. This says you can go back fourteen days.
“[Senator]: Just give me the example.
“[Keene]: Worker files a claim based on a recent visit to a physician and says, I had this problem a couple of years ago * * * and doctor says, in my opinion, this person couldn’t work as of a year ago based on that condition or injury.
“[Senator]: Evaluation today?
“[Keene cont.]: And I’m authorizing retroactive time loss. This section says you can’t do that more than fourteen days back. If somebody is that badly off that they need time loss, they should see a physician to get authorization for the time loss. And it’s reasonable for someone who has been hurt— they went home for a few days, they were in bed and weren’t getting [doctor’s care] — to take a few days to get to the doctor so that’s why the fourteen days * * *.
“[Senator]: Actually that was clarified to me after I asked the questions. Well, that kind of a situation — yes, you could get hurt and then later go to the doctor and it could be a few days. So that actually made sense.
«* * * * *
*52“[Keene cont.]: This does not affect the time limit for making a claim. It just affects how far back a doctor can give you time loss.
“[Senator]: For time loss. I see. Okay.” Tape recording, Joint Meeting of Senate Committee on Labor and Government Operations and House Committee on Labor, February 17,1995, Tape 48B.

Later, Mannix stated in support of the bill:

“* * * [TJhere have been ludicrous situations where the worker doesn’t go to a physician for a couple of months on the initial claim, and the physician said, oh yeah, I’ll retroactively authorize time loss all the way back. This makes it clear that you can only do that up to 14 days. If someone really needed to be off work, they should be seeing an attending physician.” Tape Recording, House Committee on Labor, March 6,1995, Tape 46A.

As indicated previously, ORS 656.268 addresses the process of claim closure, including the procedure for determining awards of permanent disability, termination of temporary total disability and the events that result in termination of benefits. ORS 656.268(3) was amended as part of the 1995 changes. It now provides, in pertinent part:

“(3) Temporary total disability benefits shall continue until whichever of the following events first occurs:
* * * *
“(d) Any other event that causes temporary disability benefits to be lawfully suspended, withheld or terminated under ORS 656.262(4) or other provisions of this chapter.”

As a result of the above amendment, temporary disability benefits are terminated not only when the worker returns to work or is released to return to work, but upon the occurrence of the events enumerated in ORS 656.262(4).5 The incorporation of ORS 656.262(4) events into ORS 656.268(3) as *53events that act to terminate the obligation to pay temporary disability is a manifestation of the legislature’s intention that closure orders be precluded from awarding time-loss benefits for any period of time during which there is no procedural entitlement. Thus, the legislative history when read with the text and context of the applicable statutes makes it clear that the reference in ORS 656.262(4)(g) to ORS 656.268 was intended to limit the award of retroactive time loss to 14 days, whether the claim was open or was pending closure.

The dissent contends that our decision in this case should be controlled by our holdings in Shaw v. Rebholz, 152 Or App 328, 954 P2d 190 (1998) and Santos v. Caryall Transport, 152 Or App 322, 954 P2d 187 (1998). In Shaw, the issue was whether the employer could be ordered to make temporary partial disability payments beyond the date that the claimant became medically stationary. The claimant contended the Board was precluded from determining that he was not entitled to benefits after that date because, in an earlier proceeding, it had concluded that the employer had improperly terminated claimant’s benefits. The Board concluded that ORS 656.268 as amended by the 1995 Legislature continues to address a claimant’s entitlement to benefits awarded at closure, and it ruled that claimant was not entitled to benefits beyond the date that he was disabled. On review, we summarily rejected the claimant’s argument that the distinction between “substantive” and “procedural” entitlement had been legislatively overruled by the 1995 Legislature by citing to Santos.

In Santos, the issue was again whether an employer could be ordered to pay temporary partial disability payments beyond the date that the claimant was medically stationary. He argued that he was entitled to temporary disability benefits because amended ORS 656.268 no longer provides for the termination of benefits at the time that a claimant becomes medically stationary. He also argued that ORS 656.262(4)(g) could not be applied to him retroactively. *54We did not decide the latter argument. Rather, we cited a number of cases that had been decided since the 1995 amendments, and we concluded that claimant’s arguments were controlled by our holding in Lebanon Plywood v. Seiber, 113 Or App 651, 833 P2d 1367 (1992). In that case, we held that the claimant’s substantive entitlement to temporary benefits ended on the medically stationary date, and that the Board lacked the authority to order an employer to pay benefits beyond that date.

Our holdings in Santos and Shaw are not controlling.6 Whether a claimant is entitled to benefits after becoming medically stationary is not the issue. As to the award of retroactive time loss, the legislature’s intent is clear that ORS 656.262(4)(g) provides a limitation on all awards of temporary disability under ORS 656.268. Under ORS 656.262(4)(g), the passage of time acts by operation of law to restrict the retroactive authorization of time loss. Consequently, claimant’s physician was without authority to authorize temporary disability retroactively for a period of more than 14 days. We conclude that the Board erred when it ruled that claimant was entitled to-substantive temporary disability from May 11,1993, through April 24,1995.7

Reversed and remanded for reconsideration.

1 During the time in question, the statute was numbered ORS 656.262(4)(f). In 1997, ORS 656.262(4)(g) (1995) was renumbered to ORS 656.262(4)(g). Or Laws 1997, ch 639, § 7. We refer to it by its current number.

We held in Jensen that ORS 656.262 (4)(g) applied retroactively to existing claims and that the statute, “creates a limit on the amount of retroactive benefits to which claimant is entitled, i.e., two weeks. That limit, defining as it does a claimant’s rights, is substantive.” 152 Or App at 453.

For purposes of this opinion and in the legislative history, “time loss” is a term encompassed in the term “temporary disability” compensation or TPD.

Apparently, the dissent would hold that when the legislature used ORS 656.268 in the language of ORS 656.262(4)(g), it really meant to say “ORS 656.268(3)(d).” Presumably, the legislature knows how to specifically incorporate a subsection of a statute into another statute. If the legislature had intended ORS 656.262(4)(g) to incorporate only ORS 656.268(3)(d), it would have said so.

ORS 656.268(3) provides, in its entirety:

“Temporary total disability benefits shall continue until whichever of the following events first occurs:
“(a) The worker returns to regular or modified employment;
“(b) The attending physician advises the worker and documents in writing that the worker is released to return to regular employment;
“(c) The attending physician advises the worker and documents in writing that the worker is released to return to modified employment, such *53employment is offered in writing to the worker and the worker fails to begin such employment; or
“(d) Any other event that causes temporary disability benefits to be lawfully suspended, withheld or terminated under ORS 656.262(4) or other provisions of this chapter.”

The legislature makes law by enacting new statutes. When it acts, our task is to interpret what the legislature has done by giving effect to the legislature’s intention. It is beyond our authority to create law based on a statute that is different from what the legislature intended. ORS 174.010; ORS 174.020. Although the dissent believes that essential to the determinations in the decisions in Santos and Shaw was a distinction between substantive and procedural entitlement to temporary disability benefits, neither opinion expressly considers the legislature’s intent in that regard. Moreover, our prior case law is of no consequence when the legislature acts anew, as it did here. Because of the 1995 amendment to ORS 656.262, the rule of stare decisis is inapplicable. The dissent’s analysis based on those precedents necessarily fails in light of the ambiguity of ORS 656.26214Xgl, which requires us to discern the legislature’s intent from the legislative history underlying the amendment.

Employer paid temporary loss benefits after April 24,1995.