Haller v. Champlain College

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Claimant Kimberly Haller was an employee of Champlain College when she suffered a work-related injury. Claimant had taken numerous courses at Champlain College pursuant to its “Tuition Benefits” policy. In the twenty-six weeks prior to her injury, claimant completed over ten credits of classwork at the College. The issue presented to the Department of Labor on cross-motions for summary judgment was whether the value of these tuition benefits should be included in the calculation of claimant’s average weekly wage for the purposes of her permanent partial disability benefit. The Commissioner concluded the tuition benefits was an “other advantage” that constituted part of claimant’s wages. The College argued on appeal the tuition benefit was not an "other advantage," nor did it amount to "remuneration" as defined in the applicable workers' compensation laws. The Vermont Supreme Court agreed with the Commissioner that where the non-health-insurance benefits at issue had actual monetary value and were actually received by the employee, they fell within the broad “other advantages” language. The Court concluded the Commissioner's determination was not unreasonable and affirmed. View "Haller v. Champlain College" on Justia Law