JCC Finds Pacemaker-Treated Arrhythmia Compensable Heart Disease

In Marshall v. Polk County Board of County Commissioners/Commercial Risk Management, Judge Brian J. Anthony addressed whether a former law-enforcement officer's chronotropic incompetence, sick sinus syndrome, and symptomatic bradycardia qualified as heart disease under Florida's Heart/Lung Bill.

The employer/carrier had accepted hypertension but disputed compensability of the arrhythmia-related cardiac condition. The claimant relied on medical testimony that the condition involved the heart's electrical system, required a pacemaker, and impaired the heart's ability to increase output during activity.

The JCC distinguished North Collier Fire Control and Rescue District v. Harlem, finding that this case involved the heart itself rather than an aortic aneurysm outside the heart. The order concluded that the sinoatrial-node/electrical abnormality was a functional abnormality of the heart and satisfied the statutory heart-disease presumption.

The order accepted a 2% impairment rating for accepted hypertension and a 29% whole-person rating for the arrhythmia condition. The employer/carrier was ordered to pay additional impairment benefits under the combined-rating section of the impairment guides.

The claims for compensability and authorization of care for symptomatic bradycardia and chronotropic incompetence were granted. Hyperlipidemia, penalties, and interest were denied, while attorney's fees and costs were granted for benefits secured. OJCC Case No. 24-020672BJA.

Source: Compensation Order