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Resolution No. 80982 3 4 5 6 7 81 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RESOLUTION NO. 8098 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON GRANTING THE DISABILITY RETIREMENT OF RANDY BOHLANDER, A LOCAL SAFETY MEMBER EMPLOYED BY THE CITY OF VERNON (Government Code Sections 21154 and 21156) WHEREAS, the City of Vernon (hereinafter referred to as "Agency") is a contracting agency of the Public Employees' Retirement System; and WHEREAS, the Public Employees' Retirement Law requires that a contracting agency determine whether an employee of such agency in employment in which he is classified as a local safety member is physically or mentally incapacitated to perform his duties for purposes of the Public Employees' Retirement Law; and WHEREAS, by Minute Order on October 23, 2002, the Agency approved advanced disability pension payments to Randy Bohlander employed by the Agency in the position of Fire Engineer in the Vernon Fire Department; and WHEREAS, the Agency, pursuant to Government Code Section 21152'(c), applied to the Public Employees' Retirement System ("PERS") on behalf of Mr. Bohlander for disability retirement on September 5, 2002; and WHEREAS, by letters dated October 10, 2002 and October 29, 2002, Bruce V. Malkenhorst, City Administrator, notified Mr. Bohlander that the matter of his disability retirement would be considered by the City Council; and WHEREAS, the City Council of the City of Vernon has reviewed medical evidence and other evidence relevant to whether Mr. Bohlander 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 was incapacitated. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF VERNON AS FOLLOWS: SECTION 1: The City Council of the City of Vernon hereby finds and determines that Randy Bohlander is disabled within the meaning of the Public Employees' Retirement Law from the performance of his duties in the position of Fire Engineer in the Vernon Fire Department. SECTION 2: The City Council of the City of Vernon hereby finds and determines that such disabilities are industrial, in that they are the result of injury or disease arising out of and in the course of employment, that neither the City Council of the City of Vernon nor Mr. Bohlander has applied to the Workers' Compensation Appeals Board for a determination pursuant to Government Code Section 21166 to determine whether such alleged disability is industrial, and that there is no possibility of third -party liability in this case. SECTION 3: The City Council of the City of Vernon hereby determines from the reports of Dr. Stanley J. Majcher dated October 30, 2002, November 1, 2002 and November 6, 2002, that Mr. Bohlander is unable to perform the essential job function of his position as a Fire Engineer in the Vernon Fire Department, that no appropriate reasonable accommodation can be made to do so and that the permanent and stationary date for retirement purposes is October 29, 2002. The City Council therefore determines that Mr. Bohlander should be retired. The last day Randy Bohlander was on the City',s payroll was September 3, 2002, and Mr. Bohlander retired effective September 4, 2002. - 2 - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SECTION 4! The City Clerk shall notify Mr. Bohlander of the City Council's determination granting his application for disability retirement. SECTION 5: The City Clerk of the City of Vernon shall certify to the passage of this resolution, and thereupon and thereafter the same shall be in full force and effect. APPROVED AND ADOPTED this 6th day of November, 2002. ATTEST: BRUCE V. MALKENHORST, City Clerk v LEONIS C. MALBURG, Ma or - 3 - I� 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 +' 17 18 19 20 21 22 23 24 25 26 27 28 STATE OF CALIFORNIA ) ) ss COUNTY OF LOS ANGELES ) I, BRUCE V. MA.LKENHORST, City Clerk of the City of Vernon, do hereby certify that the foregoing Resolution, being Resolution No. 8098, was duly adopted by the City Council of the City of Vernon at a regular meeting of the City Council duly held on Wednesday, November 6, 2002, and thereafter was duly signed by the Mayor of the City of Vernon. (SEAL) BRICE V. MALKENHORST, City Clerk - 4 - SUPPORTING DOCUMENTS I •� e CITY COUNCIL LEONIS C. MALBURG Mayor THOMAS A. YBARRA Mayor Pro-Tem WM. `BILL" DAVIS Councilman H. "LARRY" GONZALES Councilman W. MICHAEL MCCORMICK Councilman BRUCE V. MALKENHORST City Administrator/City Clerk FAX (323) 826-1438 REcpn Ep EDUARDO OLIVO City Attorney FAX: (562) 869-1883 72 KEVIN WILSON Director of Community Services & Water OFFICE FAX: (323) 826-1435 CITY HALL 4305 SANTA FE AVENUE, VERNON, CALIFORNIA 90058 TELEPHONE (323) 583-8811 November 6, 2002 Sent Via Facsimile & U.S. Mail (909) 860-3995 facsimile Martin Vega Colen & Lee 1470 South Valley Vista Drive Suite 230 Diamond Bar, California 91765 KENNETH J. DeDARIO Director of Municipal Utilities FAX: (323) 826-1425 STEVEN E. PARKER Fire Chief FAX: (323) 826-1407 BRUCE W. OLSON Police Chief FAX: (323) 826-1481 .V' VP Re: Request for Medical Records With Respect to the City of Vernon (the "City") Safety Member's Application for Disability Retirement Determination Dear Mr. Vega: Per our conversation yesterday, we 'believe that there has been unnecessary confusion regarding the City's ability to receive copies of medical records in connection with its determination of whether or not a safety member is "disabled" pursuant to Section 21156 of the Government Code. For -the reasons set forth below, we believe (a) that the City is required to have such information in order that it may make its determination based upon substantial evidence and (b) that providing such information to the City will not violate the confidentiality provisions applicable to Third Party Administrators in regard to medical records of workers' compensation applicants. 'Coles and Lee November 6, 2002 Page 2 Analysis Mr. Bohlander has applied for disability retirement under the Personnel Employees Retirement System ("PERS"). Upon receipt of the employee's application for disability retirement, the City is required to make a determination of "disability" based on the employee's medical records which indicate whether said applicant is physically or mentally incapacitated for the performance of said applicant's usual duties. Without such information, the City lacks a substantial basis to upon which to make an evidentiary finding for purposes of PERS. A. Confidentiality of Employee Medical Records Colen and Lee in correspondence dated January 20, and April 10, 2000, stated that "new legislation substantially expanded the confidentiality of medical records laws, as discussed in the California Labor Code § 3762." Colen and Lee concluded that such legislation provides that Third Party Administrators "are now prohibited from providing to employers, medical reports, medical bills, or medical record summaries which include an employee's diagnosis or medical history" and that there is no exception in the Labor Code which gives the Third Party Administrator the right to provide the employer with copies of medical reports or medical histories. We disagree with these statements and do not believe that Labor Code § 3762 is dispositive on the issue of an employee's responsibility to submit his medical records in connection with disability retirement under PERS. First, the Government Code sections discussed below and not the Labor Code control with regard to disability retirement under PERS. The California Supreme Court has stated that the workers compensation scheme under the Labor Code "does not extend, either expressly or impliedly, to retirement disability under the PERS law, a different legislative scheme." See Pearl v. Workers' Compensation Appeals Board et al. (2001) 26 Cal. 4t 189, 196. Although the workers' compensation law in the Labor Code and the PERS law in the Government Code are not coordinated in all respects and are administered by independent boards, it is clear that they supplement each other. The jurisdiction of the Workers' Compensation Appeals Board is exclusive only in relation to its own objectives and purposes and at the very most overlaps the subject matter ` Colen and Lee November 6, 2002 Page 3 jurisdiction of the pension board on a single issue of fact only, the issue as to whether an injury or disability is service -connected. Reynolds v. City of San Carlos (1981) 126 Cal. App. 3d 208, 213. Thus, the Labor Code section cited by Colen and Lee does not restrict the Third Party Administrator with regard to the particular disability retirement determinations at issue here. Moreover, the exception at Labor Code § 3762(c)(2) provides that the Third Party Administrator shall disclose medical information to the City "regarding the injury for which workers' compensation is claimed that is necessary for the employer to have in order for the employer to modify the employee's work duties." Here, the City will make a determination to modify the employee's work duties by determining his or her incapacity. Consequently the Third Party Administrator should provide the City with the employee's medical records for purposes of the determination which the City is required to make. This conclusion is consistent with the more general proposition that one's medical records are not discoverable unless put at issue by the person seeking the confidentiality protection. See Britt v. Superior Court of San Diego (1978) 20 Cal. 3d 844 (Court finding that there is no privilege as to a communication relevant to an issue concerning the condition of the patient if such issue has been tendered by the patient). Here, since the employee is asking for the City to determine his "disability" the employee puts his medical records with respect to his disability at issue. B. A Local Safety Employee Applying for Disability Retirement Must Submit Substantial Evidence to the City California Government Code § 20026 provides that "disability" and "incapacity for performance of duty" as a basis of retirement, mean Disability of permanent or extended and uncertain duration, as determined... in the case of a local safety member by the governing body of the contracting agency employing the member, on the basis of competent medical opinion. [Emphasis added.] Colen and Lee November 6, 2002 Page 4 This section sets forth the definition of "disability"; Government Code § 21156 additionally provides that the City shall make the determination of `disability." Section 21156 again states that the City, as the governing body of the contracting agency, is entitled to medical records of a safety employee for purposes of disability retirement under PERS: If the medical examination and other available information show to the satisfaction of... in the case of a local safety member, other than a school safety member, the governing body of the contracting agency employing the member, that the member is incapacitated physically or mentally for the performance of his or her duties in the state service and is eligible to retire for disability, the board shall immediately retire him or her for disability.... [Emphasis added.] Based upon the evidence presented by the employee, the City, as the "contracting agency," must make a determination. See, e.g., Watkins v. City of Santa Ana et al. (1987) 189 Cal. App. 3d 393 (Court finding that the initial determination of whether a local safety employee is disabled from performing his job is made by the city, not the Workers' Compensation Appeals Board). The Government Code provides that as the agency responsible for determining disability, the City is required to conduct an evidentiary hearing and any ensuing determination must be based on an employee's medical records. The City Council cannot make a determination of industrial disability if there is no evidence to support such a determination. I also note that the City may not base its determination solely on the advice of the City's Workers' Compensation attorney. Such advice is not evidence. Although not specifically stated in the Government Code, the burden of proof is on the employee to establish his right to disability retirement. See Evidence Code § 500; Cornell v. Reilly (1954) 127 Cal. App. 2d 178, 184 (Court finding that in administrative proceedings, the burden of proof is upon the party asserting the affirmative). Such proof cannot be based on surmise or conjecture, suspicion or theoretical conclusions, or uncorroborated hearsay. Id. If the employee fails or refuses to submit medical records, there is no basis for the City to make any determination. In such a situation, I ♦ . - Colen and Lee November 6, 2002 Page 5 the City would have to deny the employee's application for disability because there would be no basis upon which to make a positive determination of disability. Conclusion Our recommendations in light of our review of the law in this area are as follows: 1. Forward any and all medical reports with respect to a City employee applying for disability retirement to my office so that the City may promptly address determine whether such employee is "incapacitated" for purposes of disability retirement under PERS. 2. We will notify any employee who has applied for disability retirement of his or her obligation to submit medical examination reports and other available information with regard to his or her disability retirement claim. If you have ongoing confidentiality concerns with regard to specific records, we could ask for a release of such records from the employee. Please do not hesitate to call me if you have any questions with regard to these matters. Sincerely, r (,• Q� Eduardo Olivo City Attorney CC: John Tharp - via facsimile only (714) 573-9131 City Administrator Joan Francone, Personnel Assistant