G & J Antoniou t/as Victory Auto Repairs v Nazifi
[2005] NSWWCCPD 87
•17 August 2005
WORKERS COMPENSATION COMMISSION
APPEAL AGAINST A DECISION OF THE COMMISSION CONSTITUTED BY AN ARBITRATOR
CITATION:G & J Antoniou t/as Victory Auto Repairs v Nazifi [2005] NSW WCC PD 87
APPELLANT: G & J Antoniou t/as Victory Auto Repairs
RESPONDENT: Amir Nazifi
INSURER:Allianz Australia Ltd
FILE NUMBER: WCC1161-04
DATE OF ARBITRATOR’S DECISION: 2 August 2004
DATE OF APPEAL DECISION: 17 August 2005
SUBJECT MATTER OF DECISION: Change of circumstances: section 55 of the Workers Compensation Act 1987
PRESIDENTIAL MEMBER: Acting Deputy President Robin Handley
HEARING:On the papers
REPRESENTATION: Appellant: Vardanega Roberts, Solicitors
Respondent: McClellands, Lawyers
ORDERS MADE ON APPEAL: Clauses 1 and 3 of the decision of the Arbitrator dated 2 August 2004 are confirmed. Clause 2 of the decision is revoked.
The Appellant, G & J Antoniou t/as Victory Auto Repairs, is to pay the Respondent, Mr Nazifi’s costs of the appeal as agreed or assessed.
BACKGROUND TO THE APPEAL
On 30 August 2004, G & J Antoniou, trading as Victory Auto Repairs (‘the Employer’), sought leave to bring an ‘Appeal Against Decision of Arbitrator’ in the Workers Compensation Commission (‘the Commission’) in respect of a decision dated 2 August 2004.
The Respondent to the Appeal is Amir Nazifi, who was born on 4 April 1951 and is aged 54. He is married with three children. Mr Nazifi injured his neck and back in an accident on 15 July 1980 while working for Victory Auto Repairs as a motor mechanic installing a gearbox in a car. He received treatment for the injury but continued in that employment until August 1980. In about 1992, Mr Nazifi commenced employment as a motor mechanic for Balmain Rentals and was their head mechanic at the time of his resignation from that employment, which took effect from 23 February 2004. Although as head mechanic he performed less mechanical work than might otherwise have been the case, he worked 45 to 50 hours a week and claimed that pain as a result of the 1980 injury was giving him significant problems and he could no longer handle the work. In March 2004, Mr Nazifi recommenced employment with Victory Auto Repairs working four days a week.
In 1981, Mr Nazifi lodged a claim for workers compensation under the Workers Compensation Act 1926 with the then Workers Compensation Commission of NSW. On 26 November 1981, His Honour Judge Moroney found that Mr Nazifi “suffered a musculoligamentous injury to his lower back in the accident on 15th July 1980”, that he was totally incapacitated for work from 14 October 1980 to 31 March 1981 and partially incapacitated for work from 1 April 1981 to date and continuing. In respect of the period from 1 April 1981 to date and continuing, His Honour made an award of $107.50 per week, as adjusted. He also ordered the Employer to pay Mr Nazifi’s hospital and medical expenses. (This award is still applicable by virtue of the transitional provisions contained in Schedule 6 of the Workers Compensation Act 1987 (‘the 1987 Act’).) On 13 June 1989, His Honour, sitting in the Compensation Court of NSW, heard an application to reduce or terminate Mr Nazifi’s weekly payments by reason of change of circumstances. His Honour found there had been a change of circumstances and varied the award in favour of Mr Nazifi to a weekly payment of $100. Then on 2 June 1995, Geraghty J in the Compensation Court further varied the award by reducing it “to $45 per week as from 11 January 1993, such weekly payment to continue in accordance with the provisions of the Act”.
On 19 January 2004, the Employer’s ‘Application to Resolve a Dispute’, in respect of an application under section 55 of the 1987 Act to vary or terminate ongoing weekly payments to Mr Nazifi of $45 from 1 June 2002 to date, and ongoing medical, hospital and related expenses, was registered by the Commission. Mr Nazifi’s ‘Reply’ was lodged on 6 February 2004. On 16 June 2004, the Arbitrator conducted a teleconference with the parties, at which he granted leave to Mr Nazifi’s solicitors to amend their ‘Reply’ to include the issues of whether an epidural spinal stimulator and/or osteopathic treatment were reasonably necessary for Mr Nazifi. On 8 July 2004, conciliation having proved unsuccessful, the Arbitrator conducted an arbitration hearing. He gave an ex tempore decision at the conclusion of the hearing, the terms of which were confirmed in the Certificate of Determination set out below.
THE DECISION UNDER REVIEW
The Certificate of Determination, dated 2 August 2004, records the Arbitrator’s orders as follows:
“1. Application dismissed.
2. The applicant to pay the respondent’s expenses under section 60 of the Workers Compensation Act in respect of the provision of 26 osteopathic treatments per annum on production of accounts or receipts.
3. The applicant to pay the respondent’s costs as agreed or assessed.
I certify the matter as complex. It required a careful consideration of previous awards of the Court, detailed examination of wage records and in addition a review of medical records back to 1981 was required by both parties.”
In his brief Statement of Reasons, the Arbitrator said he made the following findings:
“1. I am not satisfied pursuant to section 55 of the Workers Compensation Act 1987 that the applicant has demonstrated a change of circumstances sufficient to vary the existing award of the Court in respect of weekly payments to the respondent which is to remain at $45 per week.
2. I am not satisfied on the balance of probabilities at this time that the provision of an epidural spinal cord stimulator is reasonably necessary under the existing award of the Court.
3. I find that the provision of up to 26 osteopathic treatments per annum is reasonably necessary under the existing award of the Court.
4. Applicant is to pay the respondent’s costs as agreed or assessed.”
ISSUES IN DISPUTE
The issues, according to the Arbitrator, were, first, whether, because of a change of circumstances, Mr Nazifi’s weekly payment of $45 should be reduced to nil, and second, whether the Employer was liable for further medical, hospital or related expenses pursuant to section 60 of the 1987 Act, in particular whether osteopathic treatment and an epidural spinal stimulator were reasonably necessary treatment expenses.
In relation to the Appeal, the Employer submits the Arbitrator made three factual errors and five errors of law in his decision. The alleged errors of law raise questions as to the adequacy of the Arbitrator’s Statement of Reasons and as to whether an estoppel arises in relation to previous proceedings. The alleged factual errors are in relation to the cause of Mr Nazifi’s current incapacity and the need for osteopathic treatment. The specific grounds of appeal and the parties’ submissions on these grounds are discussed more fully below.
ON THE PAPERS REVIEW
Section 354(6) of the Workplace Injury Management and Workers Compensation Act 1998 (‘the 1998 Act’) states:
“(6)If the Commission is satisfied that sufficient information has been supplied to it in connection with proceedings, the Commission may exercise functions under this Act without holding any conference or formal hearing.”
I have had regard to Practice Directions Numbers 1 and 6, the documents that are before me, and the submission by the parties. The Employer submits that an oral hearing is appropriate:
“given the demands of procedural fairness in the particular circumstances of this appeal involving a transcript of the arbitration, scant or absent reasons as set out in the ex tempore Judgment and the grounds of appeal involving consideration of three previous judgments of the Compensation Court and the effect of any estoppels arising out of those judgments.”
Mr Nazifi’s solicitors have no objection to additional oral submissions being made.
Having considered these submissions and the parties’ written submissions on the substantive issues, I am satisfied that I have sufficient information to proceed ‘on the papers’, without holding any conference or formal hearing, and that this is the appropriate course in the circumstances.
Neither party sought to adduce fresh evidence.
LEAVE
Before proceeding to deal with an appeal, the Commission must determine whether the application meets the requirements of section 352 of the 1998 Act. The Appeal was lodged within 28 days of the Arbitrator’s decision in compliance with section 352(4) of the 1998 Act. With regard to section 352(2), according to the Employer, the amount of compensation at issue exceeds $5,000 ($45 per week from 1 June 2002 for 114 weeks, totalling $5,130) and comprises 100% of the amount awarded by the Arbitrator. I am therefore satisfied that the section 352 threshold has been met, and I grant leave to appeal.
SUBMISSIONS
The Employer’s first ground of appeal is that the Arbitrator made an error of law by failing to give adequate reasons for finding the Employer had failed to demonstrate a change of circumstances pursuant to section 55 of the 1987 Act. Mr Nazifi’s solicitors reject this. They contend the Arbitrator’s reasons (at pages 34 to 35 of the arbitration hearing transcript (‘the transcript’)) are adequate and support his findings.
The Employer’s second ground of appeal is that the Arbitrator made a factual error by failing to determine the extent of Mr Nazifi’s partial incapacity, in particular his current probable earnings but for the injury from June 2002 to the date of the arbitration, and his current earning capacity or actual earnings for the same period. Mr Nazifi’s solicitors contend that, having found no change of circumstances, it was unnecessary for the Arbitrator to make such findings.
The Employer’s third ground of appeal is that the Arbitrator made an error of law by failing to give any or adequate reasons for preferring the opinions of Dr Bleasel. Mr Nazifi’s solicitors reject this and point to the Arbitrator’s discussion of this at page 34 of the transcript.
The Employer’s fourth ground of appeal is that the Arbitrator made an error of law by failing to give any or adequate reasons for holding there was no change of circumstances in respect of its submission that Mr Nazifi’s current incapacity is unrelated to the 1980 injury found by Judge Moroney. Mr Nazifi’s solicitors repeat their submissions in relation to the first and third grounds of appeal.
The Employer’s fifth ground of appeal is that the Arbitrator made a factual error by failing to find that Mr Nazifi’s current incapacity is wholly or partly the result of other conditions and unrelated to the musculo-ligamentous injury from 1980. Mr Nazifi’s solicitors reject this: the Arbitrator relied on Dr Bleasel’s opinion (report dated 2 March 2004 at page 6) in this regard.
The Employer’s sixth ground of appeal is that the Arbitrator made an error of law by failing to hold that Mr Nazifi was “estopped from relying upon evidence of incapacity resulting from injury other than as alleged” in relation to the 1980 application. Mr Nazifi’s solicitors note that estoppel has never previously been raised by the Employer in the current proceedings and contend it cannot now be relied on.
The Employer’s seventh ground of appeal is that the Arbitrator made an error of law by holding that osteopathic treatment was reasonably necessary in the absence of any medical evidence to support this. Mr Nazifi’s solicitors submit that such a finding was open to the Arbitrator on the evidence before him, and refer to the Arbitrator’s statement that he is “taking into account the reports of Dr Kevin Bleasel, where he recommends on a number of occasions that the osteo treatment should be made”: transcript page 36 to 37.
The Employer’s eighth ground of appeal is that the Arbitrator made a factual error by failing to find the osteopathic treatment was directed to treatment of the musculo-ligamentous injury and/or in finding the Employer was liable to pay the costs of 26 treatments in the absence of probative evidence that such costs had been incurred and that treatment of that nature and duration was reasonably necessary. Mr Nazifi’s solicitors repeat their previous submissions, above.
EVIDENCE
The evidence before the Arbitrator comprised statements from Mr Nazifi dated 6 February 2004 and 20 June 2004, a statement provided by Sam Cavallaro dated 30 June 2004 about wages for experienced motor mechanics, and what the Arbitrator described as “a wealth of medical reports” covering the period between the date of injury on 15 July 1980 and the date of the arbitration hearing. In the course of his ex tempore statement of reasons, the Arbitrator referred to medical reports filed by both parties, and discussed reports from Dr Kevin Bleasel, Mr Nazifi’s treating Neurosurgeon from 31 August 1982, Dr John Ditton, Consultant in Pain Management (Mr Nazifi’s treating specialist, to whom he was referred by Dr Bleasel), Dr Martin McGee-Collett, Neurosurgeon, and Dr Anthony Smith, Orthopaedic Surgeon.
The Arbitrator had before him judgments from the previous court proceedings concerning Mr Nazifi’s injury, he heard oral evidence from Mr Nazifi and submissions from the parties, including on the medical evidence, and the Employer also provided extensive written submissions to support its case.
Mr Nazifi gave evidence that he resigned from his position as head mechanic for Balmain Rentals because the work was too heavy for him and he could not handle it any more. Balmain Rentals allowed him time to have treatment when necessary, such as injections for pain management, and he worked for them for 45 to 50 hours a week without payment for overtime. He worked without complaint because he was afraid that “nobody else would offer me the [sic] job” (transcript page 14). Gearboxes were put on the bench for him to work on, although some of his work was of a supervisory nature. He had three apprentices under his supervision.
Mr Nazifi said after he got home from his holidays in February 2004, and his resignation took effect from 23 February 2004, he went to see his ex-boss’s son at Victory Auto Repairs and started working there four days a week from 8 March 2004 (transcript page 19). He deliberately chose to work fewer hours in order to reduce his pain.
Mr Nazifi described the pain relief he gets from osteopathy, which also makes him more flexible. However, because the relief is increasingly short-lived, he needs osteopathy more often. He said he needs such treatment twice a week, although he later said 20 times a year, at a cost of $45 per treatment (transcript pages 21 to 22). Mr Nazifi confirmed he also has had injections in his spine to assist in pain management, initially from Dr Bleasel but more recently from Dr Ditton.
Dr Bleasel provided a detailed report, dated 2 March 2004, setting out the history of Mr Nazifi’s condition. This includes reference to Mr Nazifi having beneficial osteopathic treatment from as early as 1989. Dr Bleasel said:
“I believe that as a result of the original injury, he suffered disc damage and nerve root irritation affecting the lumbar nerve roots, but also he must have suffered some strain to the thoracic and cervical regions. It is possible to have facial pain from a cervical musculoligamentous, or disc lesion …
I have read the report of Dr Anthony LF Smith … Although I cannot explain his [Mr Nazifi’s] lack of response to treatment, I have never been of the opinion that Mr Nazifi is malingering. I think he genuinely wants to be able to do his full work and although I am not any longer his treating doctor he does still come to me periodically more for encouragement than for any other reason.”
In a report dated 22 June 2004, in answer to questions, Dr Bleasel said he had always found Mr Nazifi to be a man who wanted to work despite his disability. He said:
“I have always supported Mr Nazifi in his request to have osteopathy as he has regularly found benefit from this therapy and I believe that according to his symptoms he derives benefit and therefore it should be continued.”
In a report dated 5 April 2004, Dr Ditton said he had been treating Mr Nazifi since 16 April 2002, after a referral from Dr Bleasel. Dr Ditton stated:
“Mr Nazifi suffered an injury at work in 1980. Subsequently he had a myodil myelogram and a discogram and as a consequence of this he currently has significant arachnoiditis. This is probably a significant cause of his pain. He also has degenerative changes involving both the intervertebral discs and the facet joints in both the neck and the lumbar spine …
I have suggested that epidural spinal cord stimulation would have the best possibility of providing him with useful relief in the long term.”
In a letter dated 20 April 2004, Dr Ditton said the cost of this procedure would be approximately $35,000 for an epidural spinal cord stimulator, plus medical and surgery fees of approximately $2,000 and four days hospitalisation.
Dr Martin McGee-Collett, in a report to Mr Nazifi’s treating doctor dated 24 February 2004, said Mr Nazifi would “probably be best advised to pursue pain management and to proceed with the placement of a spinal stimulator”.
The Employer referred Mr Nazifi to Dr T Mastroianni, Consultant Occupational Physician, for assessment. In a report dated 11 September 2002, Dr Mastroianni said in his opinion, Mr Nazifi:
“has chronic lumbosacral spinal pain secondary to arachnoiditis. The arachnoiditis appears to be a sequelae of investigation for his original back pain.”
Dr Mastroianni said Mr Nazifi had had a reasonable response to an epidural, use of a TENS machine and the medication Neurontin, with all of which he should continue, although the epidural only afforded short-term relief. However, Mr Nazifi’s presentation would not justify a spinal implant. Dr Mastroianni recommended against accepting liability for further physiotherapy which he did not consider therapeutic or of long-term benefit, although he considered hydrotherapy beneficial and recommended accepting liability for Mr Nazifi attending hydrotherapy. In a later report dated 9 March 2004, Dr Mastroianni expressly recommended against accepting liability for a spinal cord stimulator on the available evidence.
Dr Anthony Smith also assessed Mr Nazifi at the request of the Employer, and prepared a report dated 12 November 2003. Dr Smith stated:
“On the balance of probabilities the arachnoiditis is not producing any symptoms.
There is nothing objectively wrong with him on clinical examination regarding the neck, back either upper limb or lower limb.
He is manufacturing physical signs and behaving in a histrionic fashion.
I do not think he requires any treatment. …
I do not think there was any injury sustained on the 15/7/80. He may well have had minor degenerative changes in his back on that occasion and I would have thought he would have recovered in three months or less.”
In a later report dated 17 May 2004, Dr Smith stated:
“It is essentially my opinion that he has nothing wrong with him. I thought the arachnoiditis was due to the discography performed at Dr Bannister’s request a long time ago and it was highly unlikely to produce any symptoms.
There is in my opinion no clinical indication to provide him with a spinal cord stimulator. It will result in no improvement whatsoever.”
DISCUSSION AND FINDINGS
The role of the Presidential Member on appeal is to review the Arbitrator’s decision as a whole. The review is not a rehearing. In this case, the Employer must demonstrate that the decision of the Arbitrator is affected by some legal, factual or discretionary error (Allesch v Maunz (2000) 203 CLR 172; The King Island Company Limited v Deery [2005] NSW WCC PD 1) in order to enliven the Presidential Member’s power to interfere with the Arbitrator’s decision pursuant to section 352(7) of the 1998 Act.
Section 55(1) of the 1987 Act provides that “any weekly payment of compensation may, because of a change of circumstances” be reviewed by the Commission. As Deputy President Fleming said in Worthington v Alexander [2005] NSW WCC PD 12 (‘Worthington’), at paragraph 22, it is clear from the leading cases on section 55, Atlas v Bulli Spinners Pty Ltd (1993) 9 NSWCCR 378 (‘Atlas’) and George Weston Foods Ltd t/as Tip Top Bakeries v Goldsmith (1998) 17 NSWCCR 253, that:
“‘change of circumstances’ is a threshold issue to be determined prior to review under section 55 of the 1987 Act … Only where a ‘change of circumstances’ is demonstrated is the Arbitrator empowered to review the worker’s substantive entitlements to workers compensation benefits.”
The onus of proving a change of circumstances rests with the party who asserts it (Atlas). The phrase ‘change of circumstances’ must be given its ordinary meaning, understood in the context of the 1987 Act, and must be relevant to the worker’s entitlement to statutory weekly benefits (Worthington at paragraph 28). A change of circumstances could involve medical issues or incapacity, but also changes in the labour market relative to the worker’s ability to obtain suitable employment, changes in the worker’s qualifications or skills that impact on the worker’s ability to earn (for example acquired further education or training), or acceptance of an early retirement package.
Turning to the Arbitrator’s ex tempore reasons for his decision, he deals first with Dr Smith’s claim that, in the Arbitrator’s words, Mr Nazifi is “malingering”. The Arbitrator preferred to rely on Dr Bleasel’s opinion on this, noting that Mr Nazifi “had tried, where possible, to give accurate answers to the questions” put in cross-examination by the Employer’s solicitor (transcript page 34). In relation to section 55, the Arbitrator said he was satisfied from Mr Nazifi’s oral evidence that he left the employment of Balmain Rentals because “he needed to reduce the number of hours he worked” (transcript page 35). The Arbitrator was consequently not satisfied that there had been a change of circumstances that would lead him to either reduce or change the amount of weekly payments. Whilst I agree the Arbitrator’s reasons on this issue are brief, in my opinion, he did correctly address the issue and drew attention to medical evidence and Mr Nazifi’s oral evidence in support of his finding. I am not therefore persuaded that the Employer has made out its first ground of appeal. It follows that the Employer must also fail on its second ground of appeal because, having found there to be no change of circumstances, the Arbitrator was precluded from reviewing Mr Nazifi’s weekly payments and, rightly, did not do so.
With regard to the third ground of appeal, as stated above, the Arbitrator preferred Dr Bleasel’s opinion to that of Dr Smith. My reading of the medical evidence leads me to a similar conclusion to that on the first ground of appeal. Thus, the third ground of appeal is also not made out.
With regard to the fourth ground of appeal, the Employer’s submission to the Arbitrator was that there had been a twofold change of circumstances: first, Mr Nazifi was earning an income equal to or in excess of his probable earnings but for the injury and, second, in the alternative, if he was unable to earn a level of income commensurate with his probable earnings but for the injury, then such incapacity was unrelated to the musculo-ligamentous injury sustained in 1980. The first of these submissions has been dealt with in relation to the first ground of appeal, above. In relation to the second, as already noted, the Arbitrator preferred to rely on Dr Bleasel’s opinion rather than that of Dr Smith. A reading of the medical evidence indicates that it is only Dr Smith who doubts the causative link between the 1980 injury and Mr Nazifi’s present condition. For example, the archnoiditis diagnosed by Drs Ditton and Mastroianni is thought to be a direct consequence of the treatment Mr Nazifi had for the musculo-ligamentous injury that Judge Moroney found Mr Nazifi to be suffering from in 1981. Thus, in my view, it was implicit in the Arbitrator’s discussion of the medical evidence and in his findings, that Mr Nazifi’s current incapacity is related to his 1980 injury. While I agree the Arbitrator should have addressed the Employer’s submission on this issue more fully, in my view, his reasons are not so inadequate as to amount to an error of law.
Similarly, in relation to the fifth ground of appeal. The onus was on the Employer to persuade the Arbitrator that a change of circumstances had occurred. He was clearly not so satisfied. With regard to the sixth ground of appeal, in my view, current medical evidence is clearly relevant to the issue of ongoing incapacity and medical expenses, and, in any event, it would be unfair to permit the Employer to rely on such a ground when it has never previously been raised in these proceedings.
The seventh ground of appeal is founded on the premise that there was no medical evidence to support the need for Mr Nazifi osteopathic’s treatment. Mr Nazifi gave evidence as to the benefit he derives from osteopathic treatment (transcript pages 20 to 22). Dr Bleasel, in his report of 2 March 2004, referred to the benefit Mr Nazifi derives from this treatment, that he has had, at different times, since 1989. Dr Bleasel stated that such treatment should be continued. In my view, there was sufficient evidence before the Arbitrator to support his finding that osteopathic treatment is reasonably necessary and the Arbitrator did not, therefore, make an error of law in this regard.
With regard to the Employer’s final ground of appeal, in my view, it is implicit in the Arbitrator’s ex tempore statement of reasons that the osteopathic treatment is directed to the ongoing symptoms arising from the 1980 injury. As to the duration and frequency of the treatment, Mr Nazifi’s evidence at the hearing, at first, was that he needed such treatment twice a week (transcript page 21). Later, he stated 20 times a year, with each treatment costing $45 (transcript page 22), but said he would not need this if an epidural spinal stimulator were inserted (transcript page 26). The Arbitrator said he was not satisfied that a spinal stimulator was reasonably necessary, but considered it reasonably necessary for Mr Nazifi to have osteopathic treatment 26 times per year to enable him “to get some temporary relief while he looks at whether he really wants to go ahead with this stimulator”. In my view, there is nothing to suggest a factual error by the Arbitrator when he found that the proposed fortnightly osteopathic treatment is reasonably necessary.
Payments under section 60 of the 1987 Act “are to be made as the costs are incurred, but only if properly verified” (section 60(3)). The terms of the Arbitrator’s order provides for payment of Mr Nazifi’s expenses “in respect of the provision of 26 osteopathic treatments per annum on production of accounts or receipts”. In my view, while it is accepted that the Commission has the power to make a declaration that particular proposed medical or related treatment is reasonably necessary, for example, hip replacement surgery (McEvoy v Southern Cross Homes (Broken Hill) Inc [2001] NSWCC 168, at paragraph 37)), a specific award for future payment cannot be made because, as the NSW Court of Appeal held in NSW Sugar Refining Co-operative v Manning (1998) 44 NSWLR 442, section 60 is an indemnity provision. Thus, clause 2 of the Arbitrator’s determination must be revoked. However, the original 1981 award for the payment of hospital, medical and related expenses remains undisturbed.
Subject to the revocation of clause 2, the Employer not having established its grounds of appeal, the appeal must be dismissed and the determination of the Arbitrator must be confirmed.
DECISION
Clauses 1 and 3 of the decision of the Arbitrator dated 2 August 2004 are confirmed. Clause 2 of the decision is revoked.
COSTS
The Appellant, G & J Antoniou t/as Victory Auto Repairs, is to pay the Respondent, Mr Nazifi’s costs of the appeal as agreed or assessed.
Robin Handley
Acting Deputy President
17 August 2005
I CERTIFY THAT THIS IS A TRUE AND ACCURATE RECORD OF THE REASONS FOR DECISION OF ROBIN HANDLEY, ACTING DEPUTY PRESIDENT OF THE WORKERS COMPENSATION COMMISSION.
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