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Wednesday, October 17, 2012

New Case Discusses PSEBA, Catastrophic Injuries, and Medicare

In Pyle v. City of Granite City, a former firefighter filed suit to challenge the City's denial of health insurance benefits under the Public Safety Employee Benefits Act (PSEBA).  The trial court had ruled that Pyle was entitled to the PSEBA payments for life.  The City appealed, arguing that Pyle was not catastrophically injured pursuant to PSEBA and the City was not required to pay the premiums for Pyle's supplemental Medicare coverage.

The appellate court reversed in part and affirmed in part.  First, the court determined that Pyle was "catastrophically injured" and that the City was required to pay Pyle's health insurance premiums.  However, the court determined that the City was not required to pay for Pyle's supplemental Medicare coverage once he became Medicare eligible.

With respect to Pyle's "catastrophic injury," the appellate court relied on the Illinois Supreme Court's ruling in the 2003 case Krohe v. City of Bloomington that a catastrophically injured firefighter is synonymous with a firefighter who, due to injuries, had been forced to take a line-of-duty disability.  Although Granite City argued that the Supreme Court's interpretation did not comport with the commonly understood meaning of "catastrophic," the appellate court declined the City's invitation to "overrule" the Supreme Court's decision in Krohe.  Thus, because Pyle suffered a line-of-duty injury, he qualified for PSEBA benefits.

Next, the appellate court agreed with the trial court's determination that Pyle was entitled to payment of PSEBA benefits for his lifetime.  However, the appellate court determined that those benefits are reduced or may, in some cases, cease when a person becomes Medicare eligible because the statute expressly provides that health insurance benefits "payable from any other source shall reduce benefits payable" under PSEBA.  In this case, once Pyle reached age 65 and became Medicare eligible, the City's payment of PSEBA benefits were "reduced" in their entirety, meaning the City no longer was required to pay his health insurance premiums.  

Finally, the appellate court rejected Pyle's contention that the City was responsible to pay for supplemental Medicare coverage offered by the City's group plan, finding no such statutory requirement. If Pyle wanted to participate in the City's group insurance plan supplemental Medicare coverage, then he would have to pay for it.

Post Authored by Julie Tappendorf, Ancel Glink.


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