Andrea Hoch is not burdened by the niceties of the Labor Code or statutory interpretation. In providing the regulatory scheme she has demonstrated that if the facts don't fit her interpretation of the law, she will go ahead and just make something up. A case in point, the future earnings modifier of the new permanent disability rating schedule. No Rand report giving empirical support, just make something up.

Her latest effort is contained in "Answers to workers' compensation practitioners' questions about applying the permanent disability rating schedule (PDRS)." In several instances her interpretation goes beyond the plain language of the statute in its interpretation. Now, this would be fine if she was just another member of the defense bar, or the insurance adjuster community. However, people listen to this advice and follow it. This includes the disability evaluators that work for Ms. Hoch.

These continued misinterpretations of the law will keep creating chaos in a system that is already burdened by navigating the changes implemented by recent reforms. Maybe it would be better if Ms. Hoch would keep her "answers" to her self.