PREPARING FOR BATTLE TO WIN THE WAR: STRATEGIES TO LEVERAGE A GOOD RESULT Presented and Prepared by:
Craig S. Young
[email protected]
Peoria, Illinois • 309.676.0400
Heyl, Royster, Voelker & Allen
PEORIA • SPRINGFIELD • URBANA • ROCKFORD • EDWARDSVILLE
© 2010 Heyl, Royster, Voelker & Allen
15549846_5.DOCX
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PREPARING FOR BATTLE TO WIN THE WAR:
STRATEGIES TO LEVERAGE A GOOD RESULT
I.
INTRODUCTION.............................................................................................................................................J-3
II.
MAKING THE DECISION TO DEFEND ....................................................................................................J-3
A.
B.
C.
D.
E.
F.
G.
H.
III.
Controlling Medical Expense .....................................................................................................J-5
Avoid Long Term TTD Exposure ...............................................................................................J-6
Foster Positive Environment in the Workplace ...................................................................J-7
Send a Message to Petitioners’ Attorneys............................................................................J-8
Avoid Permanent Total and/or Wage Differential Exposure .........................................J-8
Keep Medicare Options Open...................................................................................................J-9
Maintain Settlement Options ................................................................................................. J-10
You Just Might Win .................................................................................................................... J-10
CONCLUSION .............................................................................................................................................. J-10
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PREPARING FOR BATTLE TO WIN THE WAR:
STRATEGIES TO LEVERAGE A GOOD RESULT
I.
INTRODUCTION
In recent years, we have discussed the impact of the Rod Blagojevich administration on workers’
compensation exposure for employers in Illinois. Without doubt, policies of the former
administration established an environment before the Illinois Workers’ Compensation
Commission which was as hostile towards employers as any other period in our state’s history.
Unfortunately, we have not seen significant change in that trend under the new administration.
Employers continue to face the most difficult workers’ compensation environment in recent
times, and perhaps ever. If anything, potential exposures presented by many workers’
compensation cases have dramatically increased in the past couple of years, due to factors
outside the workers’ compensation system, such as Medicare and healthcare issues.
In the face of these difficulties, employers, their insurance carriers, third party administrators,
and workers’ compensation managers, continue to face difficult decisions with regard to defense
and trial of cases. As potential exposures increase, and as decisions from the Workers’
Compensation Commission continue to be very employee-oriented, many employers continue
to pursue the strategy of accepting and paying most cases, regardless of legitimate defenses
which may exist. The understandable attitude of many employers is “Why should I defend a case
I know I will lose anyway?” As other presenters in this seminar have documented, there are far
too many situations in which employers are receiving unfavorable results from the Workers’
Compensation Commission in settings where viable defenses exist.
Two years ago, the author of this paper discussed the value of making the decision to defend
legitimately defensible cases, even when the potential result from the Workers’ Compensation
Commission is uncertain. As previously outlined, the leverage which can be obtained from a
viable defense can often result in significant savings, even when the result at arbitration is likely
to be unfavorable. In the two-year period since this last presentation, the potential exposures
existing for employers who simply accept and pay all claims have dramatically increased. Current
trends with Medicare issues, permanent total and wage differential exposures, long term TTD
issues, and medical treatment issues have dramatically increased the potential exposures on
cases which are voluntarily accepted. In today’s environment, the savvy employer must apply a
sophisticated analysis to every case, and make an informed decision as to how best to use viable
defenses in the ongoing effort to reduce overall workers’ compensation exposure.
II.
MAKING THE DECISION TO DEFEND
It must be stated at the outset that the decision to defend first and foremost must be based
upon an accurate analysis of the facts and the law, as it pertains to each case. It is never good
strategy to deny or defend compensable cases, and it is never good strategy to deny any
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workers’ compensation benefit, when the facts and the law indicate compensability. Such action
not only raises the potential for penalties, it simply is bad case management strategy. When a
benefit is owed, the best strategy is to pay it promptly, and then aggressively manage the case
to conclusion.
The more difficult case management decision develops in those scenarios when a legitimate
defense exists, but defense counsel is suggesting that the Workers’ Compensation Commission
might not accept that defense. Many employers in such situations opt to accept the inevitable,
save some money on defense, and voluntarily pay defensible claims before proceeding to trial
before the Workers’ Compensation Commission. This decision is often made even when there is
a good chance of prevailing before a certain arbitrator, because of a concern the favorable
decision at arbitration might be reversed on review.
As our firm has discussed in the past, in order to properly make the decision to defend or accept
compensability, the employer must look beyond the simple question of whether or not the case
will be won or lost at trial. The more important question is whether or not the ultimate expense
of the claim can be reduced through an aggressive defense. The difficulty for many employers in
making this decision is that the savings associated with an aggressive defense is not always
traceable directly to the bottom line in today’s workers’ compensation climate where many
defensible cases are lost at trial. In making the “pay or defend” analysis, employers must
consider not only the chances of winning the case and paying nothing, but also what will be
paid on the claim if defenses are abandoned and benefits are voluntarily accepted. This
calculation must include the awareness that voluntary acceptance of a defensible claim means
that TTD and medical benefits will paid until the petitioner, the petitioner’s attorney, the
petitioner’s treating doctors, and the Workers’ Compensation Commission decides those
benefits should end. Also, when a defensible claim is voluntarily accepted, employers must
understand that an elevated permanency amount will be paid pursuant to settlement, or will be
obtained by the petitioner at trial. As will be discussed below, these elevated amounts are
increasing daily, as more and more wage differential and permanent total awards are sought,
and as Medicare presents additional costs to settlement. Once a claim is voluntarily accepted,
the employer loses leverage to limit or reduce many benefits which will develop over the course
of the claim, and the employer also loses leverage to negotiate a settlement at an amount which
would be awarded by the Commission.
Clearly, in today’s environment there is little doubt that arbitration of defensible claims will
sometimes result in the case being found compensable and benefits being awarded. No
employer in today’s environment can blindly assume that an aggressive defense will always
result in a favorable decision if the case is tried. Unfortunately, this is true even as to cases which
are clearly defensible based on the law and the facts. There are far too many examples of cases
which are clearly not compensable being found compensable by our Workers’ Compensation
Commission. A decision to voluntarily accept and pay a defensible claim, however, eliminates
numerous opportunities to reduce workers’ compensation costs, and guarantees a result in
which the ultimate amount paid will be the absolute maximum. Giving up valid defenses often
reduces or eliminates the ability to manage the claim at all levels, and surrenders control of all
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TTD, medical, and permanency decisions to the petitioner, petitioner’s attorney, the petitioner’s
doctors, and the Workers’ Compensation Commission. Conversely, aggressively asserting viable
defenses will present many options throughout the pendency of the case to reduce, sometimes
dramatically, the ultimate cost of the case.
A.
Controlling Medical Expense
It is no secret that medical costs are perhaps the largest driver of workers’ compensation
expense. Even in clearly compensable cases which are accepted, aggressive strategies must be
employed to try and end medical treatment, and limit that treatment to those expenses which
are truly reasonable and necessary to cure the effects of the injury. Limiting these expenses can
be difficult, even in clearly compensable cases.
More difficult decisions arise when the work comp manager is faced with the dilemma of
approving or denying certain medical treatment on cases which are arguably defensible. We all
have experienced the situation of deciding whether to approve or deny treatment when a viable
defense exists, but defense counsel is suggesting that the defense might not be won at
arbitration. The tendency is to decide that it is better to begin the treatment immediately,
complete it as soon as possible, and then move the case toward resolution.
This decision can be especially difficult when a legitimate accident defense exists, but
preliminary medical indicates the injury might not be very serious. If it is not certain that the
accident defense would prevail, the temptation is to pay for “a little” medical, “a little” TTD, and
then resolve the case. Unfortunately, this often backfires. Once the accident defense is
conceded, it becomes difficult or impossible to raise it at a later time. Far too many workers’
compensation decision makers have been faced with the dilemma of seeing a strain case
develop into a surgical case, at which point there is regret for having given up the accident
defense. By removing the pressure of the denied case from the petitioner, as well as from the
petitioner’s doctors, it becomes far too easy for the petitioner to progress through the system
and continue to experience physical difficulty while drawing TTD. With unfortunate frequency,
the medical community remains far too likely to continually elevate the treatment levels as the
petitioner continues to complain. This occurs often, even in the absence of objective evidence to
document a condition of ill-being.
In many cases, this scenario can be controlled by asserting a valid accident defense prior to
authorizing TTD and medical treatment. It is not uncommon for a petitioner who is refused the
opportunity to progress unchallenged through the system to look for other resolution options.
Sometimes the mere presence of timing issues associated with getting a disputed case to trial
can be a factor in forcing the petitioner to bring medical and TTD to conclusion.
Even in cases which are accepted as compensable, legitimate disputes can arise as to the
reasonableness and necessity of treatment, or causal connection. Perhaps the most common
example of this is when a treater decides that conservative treatment has failed and surgery is
necessary, and a credible IME physician has rendered the opinion that surgery is not
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appropriate. It is not uncommon for defense counsel to advise that the Workers’ Compensation
Commission is likely to follow the treater’s opinion over the opinion of the IME physician. At the
same time, it is often clear in these cases that the surgery will likely not help the petitioner, and
in fact, might make the petitioner worse. As an example, there is a growing body of evidencebased medicine which documents the non-effectiveness of fusion surgeries in many
occupational injuries. Despite that growing body of evidence, we see an ever-increasing
frequency in some medical communities for fusions to be recommended on a regular basis,
simply because conservative treatment has failed. In many of these situations, it might be
appropriate to employ a strategy which is directed toward trying to keep the fusion surgery
from occurring. While this can be difficult when the Workers’ Compensation Commission is
willing to award the surgical benefit, refusing to voluntarily accept the surgery when credible
evidence questioning the necessity of the surgery exists sometimes presents opportunities to
bring a case to conclusion prior to the surgery. In some cases, this strategy can be the difference
between a settled case with closed medical, and a very expensive permanent total case with
open-ended medical exposure.
While the disputed surgical case is probably the best example of how medical containment
strategies can dramatically reduce exposure, the savvy case manager should not always accept
and authorize every conservative treatment measure recommended by treating physicians.
When credible medical evidence exists, either by way of IME testimony or UR testimony to deny
certain conservative treatments, those defenses should be asserted even in scenarios where the
potential of losing that defense at trial exists. There are ever-increasing examples of the medical
community being willing to extend therapy, work hardening, glorified chiropractic treatment,
and other pain management techniques almost forever. It also must be remembered that our
system tends to progress patients along a treatment continuum, and as conservative treatment
measures become protracted, the petitioner is simply progressing to more and more serious
treatment, ultimately leading to surgery or other more serious medical interventions. These
causal relationship and necessity of treatment issues will not always present certain results at
trial, but when credible evidence exists to refute treatment, denial of such treatment will likely be
advisable.
B.
Avoid Long Term TTD Exposure
Most good claims handlers are aware that one of the most important strategies for limiting
workers’ compensation expense is to limit TTD exposure whenever possible. It is always best to
avoid even initiating TTD, if there is evidence to support TTD denial. Most cases are not going to
progress in a positive direction, as long as the petitioner is able to continue working without
pay. Aggressively relying upon any credible evidence which may be available to support a
refusal to pay TTD is always good claims handling strategy.
Like so many other issues, there are numerous factual scenarios presented in which the Workers’
Compensation Commission would be likely to award TTD, if the issue is tried. Sometimes the
dispute may be as to overall compensability, if an accident defense exists. Other times, the
dispute may be medical in nature, and may turn on the question of disputed medical opinions
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as to whether or not the petitioner can work. Also, the employer may have a job offer available
which matches an IME physician’s restrictions, but does not match the restrictions placed on the
petitioner by the treating physicians. In many such scenarios, defense counsel may advise that
these issues are likely to be lost in front of certain arbitrators. The employer’s evidence may be
strong, but the reality may be that the Commission, in addressing the evidence, would be likely
to award the TTD benefits. In far too many situations, employers opt for voluntarily continuing
TTD in these scenarios.
Although statistical evidence to document this strategy would be impossible to compile, it is
clear that in a majority of cases, the ability to end the TTD benefit often moves the case to
resolution prior to any trial. This is often true, even when it is clear to all of the parties that the
petitioner would have a reasonably good chance of prevailing on the TTD issue at trial. The
prospect of being without a TTD check for an extended period of time while the trial and review
process takes place, is often a factor which prompts the petitioner to voluntarily return to work
and move toward case closure. As a result, claims handlers should be very aggressive at
asserting evidence which allows for termination of TTD. Special care must be taken in this
scenario to make reasonable judgments as to the evidence available on the disputed TTD issue.
An experienced claims handler will not only try to determine what the Commission’s result
might be at trial, but also try to determine what the true status of the petitioner’s inability to
work is. If the best medical evidence documents that the petitioner really isn’t capable of
returning to work, terminating TTD will likely not positively affect the outcome. It is not enough
to have some evidence to justify termination of TTD, it is important to have credible evidence.
When such evidence exists, an aggressive termination of TTD makes sense, even if there is
concern that the petitioner might win the dispute at trial.
C.
Foster Positive Environment in the Workplace
Employers often overlook the benefits to the workplace of consistently following the credible
evidence in workers’ compensation cases. Unfortunately, it is a reality that if an employer’s
workforce becomes aware that certain types of claims are automatically accepted and paid, the
frequency of those types of claims will dramatically increase. This is especially true when a
certain department or segment of the workforce is prone to similar type injuries. The best way to
insure that claims will increase in the future is to simply accept and pay any and all claims
presented regardless of the evidence.
When an employer has credible evidence to deny a case, there are benefits to asserting that
denial, even if there is a likelihood the case will be lost at trial. Fellow employees will be less
likely to file copycat claims, if they are aware the employer is ready and willing to defend those
claims and take them to trial regardless of the result. As is true with all of these disputed
situations, special care must be taken to reasonably evaluate the evidence, and to make these
compensability decisions upon that reasonable evaluation.
As was demonstrated in the Supreme Court’s recent decision in the Interstate Scaffolding case,
the courts can sometimes author decisions which are extremely problematic in the workplace.
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Some commentators on the Interstate Scaffolding case have suggested that this case stands for
the proposition that you can “hit the boss, and collect TTD.” While the Interstate Scaffolding case
certainly does not stand for that proposition, it does raise the potential argument that an
employee terminated for cause as a result of his own bad act could, in certain scenarios, receive
TTD. This case is an example of a legal principle which should be carefully analyzed in each
individual case. To the extent an employer can isolate any facts in an individual case which can
be distinguished from the facts in Interstate Scaffolding, all requests for workers’ compensation
benefits sought by employees who are terminated for their own bad acts should be denied.
Even if it is assumed that some of those denied claims would ultimately be held compensable by
the Workers’ Compensation Commission, the negative impact on overall workers’ compensation
expenses of voluntarily accepting workers’ compensation claims from petitioners who are
terminated as a result of their own bad acts could create astronomical workers’ compensation
costs in the workplace. The best strategy for reducing workers’ compensation claims in the
workplace is to consistently and fairly pay those claims which are supported by the evidence,
and consistently and fairly deny those claims which are not supported by the evidence. An
employer cannot afford to be voluntarily paying claims not supported by the evidence, simply
out of fear that the claim might be lost at trial.
D.
Send a Message to Petitioners’ Attorneys
Although of lesser importance, employers also need to be aware of those situations in which a
proper message should be sent to petitioners’ attorneys. In some settings, petitioners’ attorneys
will not be as likely to continually file claims, if they are aware the employer will assert legitimate
defenses. Conversely, some petitioner’s attorneys become aware that certain employers always
pay cases, even when defenses exist, and those attorneys therefore become prolific filers of
cases against that employer. The unfortunate reality is there are many petitioners’ attorneys who
will file workers’ compensation claims on behalf of their clients, regardless of the approach of
the employer. In some instances, however, petitioner’s attorneys, especially more accomplished
petitioner’s attorneys, will decide not to pursue certain types of claims against employers who
they know will consistently assert viable defenses. They simply make a business decision that it is
not cost-effective for them to pursue such claims.
E.
Avoid Permanent Total and/or Wage Differential Exposure
One of the most troubling trends in decisions from the Workers’ Compensation Commission
over the last couple of years has to do with the dramatic increase in the number of permanent
total and wage differential decisions. More and more petitioners have become unwilling to close
their cases for reasonable permanency amounts, and have become more aggressive at asserting
the right to long term or lifetime benefits. This trend is likely due in part to the liberalization of
the Illinois Workers’ Compensation Commission over the last couple of years, and also due to a
significant amount of advertising by petitioners’ attorneys in which the potential for lifetime
benefits is promoted. Physicians who are prone toward doing and saying what their patients
desire, often cooperate with this trend, both in terms of recommendations for never-ending
treatment, as well as opinions documenting a petitioner’s inability to return to work. The
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unfortunate reality is some employees when presented with the prospect of retiring on work
comp will aggressively pursue that option, and in far too many cases, they will be able to garner
some evidence to support their position.
This move toward more frequent attempts to obtain long term benefits such as permanent total
or wage differential benefits is one of the primary reasons for asserting viable defenses available
to the employer. Gone are the days of employees getting hurt, being treated, getting better,
returning to work, and reasonably closing their cases. While many compensable cases will
progress in that fashion, far too many cases in today’s environment appear to be simple at the
outset, only to ultimately present long term exposure. The best strategy for an employer to
avoid this scenario is to consistently and aggressively present viable defenses at every point in
the case. If a viable accident defense exists, do not initiate the payment of benefits. When a case
is compensable, be certain to aggressively assert any defense which may be available to
ongoing benefits, whether those benefits be TTD or medical. The employer, who allows the
prospect of losing an issue at trial to result in the voluntary acceptance of benefits which can be
reasonably disputed, will far too often be presented with the potential for permanent total or
wage differential exposure.
F.
Keep Medicare Options Open
One of the most difficult recent developments in workers’ compensation practice has been the
advent of Medicare’s efforts to protect their rights pursuant to the Medicare Secondary Payer
Act. Every work comp claims handler is aware of the issues presented by Medicare, and of the
difficulty the Medicare issue often presents when attempting to resolve cases. The expense of
settling cases has been dramatically increased in those settings when Medicare’s future interests
must be protected.
Numerous strategies are employed to manage the Medicare exposure as we attempt to resolve
workers’ compensation cases. Often these strategies might result in the decision not to set up a
Medicare Set-Aside trust. Obviously, when this decision has been made, there needs to be good
evidence available to support that decision. One of the most important factors which needs to
be looked at in deciding whether or not a set-aside trust should be set up for certain medical
treatment is whether or not the treatment has been consistently denied by the employer. If a
claim has been accepted, or if a medical benefit has been voluntarily accepted, that voluntary
payment might limit the ability to avoid a set-aside even when there is credible medical
evidence to dispute future Medicare exposure. In short, it is becoming more and more
important for employers to be able to document that they have consistently denied certain
treatment. In some cases, this consistent denial could be the difference between a settlement
closing all issues without a set-aside, and the inability to settle a case due to the amount of a
necessary Medicare Set-Aside.
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G.
Maintain Settlement Options
It must always be remembered that denying a workers’ compensation case or denying certain
benefits doesn’t mean that the employer will never pay anything. Often, the greatest cost
savings will be presented by a settlement and close out which would not have been available
but for the defenses previously asserted by the employer. A strategy which contemplates taking
every denied case to trial, regardless of the strength of the denial, is not likely to be effective in
an overall effort to control workers’ compensation costs. The greatest cost control strategy is
sometimes presented by the case which is settled and closed out for a lump sum after the
aggressive assertion of defenses has limited the potential for more expensive long term benefits.
The savvy claims handler will always recognize this strategic option available in those cases
which have been properly denied. It is a reality that many properly denied cases will be lost at
trial by the employer, and in those scenarios, the employer needs to keep an open mind toward
the most cost-effective resolution.
When viable defenses are asserted, the employer maintains the ability to use some creativity in
negotiating case resolution. Often an arbitrator who is very likely to decide against an employer
at trial will be much more employer friendly at a pretrial. This pretrial opportunity is lost when an
employer voluntarily gives up a defense and accepts compensability. Numerous other creative
options for case resolution will present themselves when employers properly assert viable
defenses. Very little opportunity for case closure exists when the petitioner is never challenged
and questionable benefits are paid on a voluntary basis.
H.
You Just Might Win
Of course the best reason to consistently assert viable defenses is the fact that many cases can
in fact be won before the Commission. While there is a wide variance in results expected from
different arbitrators, the employer should never give up on the possibility of winning those cases
which truly are defensible. Far too many opportunities for an outright win in a workers’
compensation case are lost due to an employer’s willingness to simply accept and pay claims
based on a belief that the Commission is going to find all cases compensable.
III.
CONCLUSION
It is no secret that the environment faced by employers before the current Illinois Workers’
Compensation Commission remains very difficult. We have not yet seen the changes necessary
to improve the environment for employers. Until such changes occur, either at the legislative or
administrative levels, it seems likely the majority of decisions from the Commission, at all levels,
will be in favor of petitioners. This unfortunately is sometimes true, even when credible evidence
in favor of the employer exists. Employers however, must continue the effort to limit and reduce
workers’ compensation costs, even in the face of this difficult legal environment. Although every
case must be judged on a case-by-case basis, it is clear that a workers’ compensation policy of
paying most cases due to a fear of losing the case at trial will be costly. While the cost of
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defense always must be factored into the claims handling analysis, the cost of that defense often
will be trivial compared to the savings available to the employer who aggressively asserts viable
defenses. As increasingly expensive issues such as sky-rocketing healthcare costs, Medicare SetAside exposure, and increased permanency values, including permanent total and wage
differential exposures, continue to develop, employers must be vigilant in attempting to control
those costs. Often, the only viable strategy available to an employer to control these costs is to
aggressively assert viable defenses, even when the chance of success at trial is uncertain.
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Craig S. Young
- Partner
Craig practices and has a leadership role in the firm's
workers' compensation and employment law practice
groups. Craig began his career at Heyl Royster as a
summer clerk while in law school and became an
associate in the firm's Peoria office in 1985. He has
spent his entire career with Heyl Royster and became
a partner in 1993. He is recognized as a leading
workers' compensation defense lawyer in the state of
Illinois and has handled all aspects of Illinois workers'
compensation litigation including arbitrations,
reviews, and appeals. He has developed expertise in
the application of workers' compensation to certain
industries including hospitals, trucking companies,
municipalities, large manufacturers, school districts,
and universities.
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In addition to his expertise in litigated cases, Craig has
developed a reputation for counseling employers
regarding overall management of the workers'
compensation risk. Through seminars and
presentations to local and national industry groups,
in-house meetings, regular claims review analysis, and
day-to-day legal counsel, Craig assists his clients in
looking beyond each individual case in an effort to
reduce overall workers' compensation expense. His
comprehensive approach to workers' compensation
issues also includes third-party liability and lien
recovery issues.
“Medical Science, Industrial Commission
Science - Understanding the Industrial
Commission's Approach to Medical Issues”
Lorman Education Services 2008
The Implications of ADA, FMLA and Collective
Bargaining Agreements on the Workers’
Compensation Claim
Defense Research Institute 2008
“The Employee Who Can't Return to Work:
Wage Differentials, Vocational Rehabilitation &
Job Placement”
Lorman Education Services 2008
“Medicare Set-Aside Agreements-The Rest of
the Story”
Defense Research Institute 2007
“Workers' Compensation and Illegal Aliens”
Defense Research Institute 2006
Professional Recognition
 Martindale-Hubbell AV Rated
 Selected as a Leading Lawyer in Illinois. Only
five percent of lawyers in the state are named
as Leading Lawyers.
 Peoria County Bar Association 2008
Distinguished Community Service Award
Professional Associations
 American Bar Association
 Illinois State Bar Association
 Peoria County Bar Association - Board Member
and Chair of By-laws Committee
 Defense Research Institute - Workers'
Compensation Steering Committee - Program
Chair
Currently, Craig serves on the steering committee for
the workers' compensation committee of the Defense
Research Institute. He also chairs DRI's Program
Committee and in that role has assisted in nationally
acclaimed teleconferences on specific issues relating
to workers' compensation defense. He has been
designated as one of the "Leading Lawyers" in Illinois
as a result of a survey of Illinois attorneys conducted
by the Chicago Daily Law Record. Craig is actively
involved in supporting many local charitable
organization and civic causes. He was the 2008
recipient of the Peoria County Bar Association's
Distinguished Community Service Award.
Court Admissions
 State Courts of Illinois
 United States District Court, Central District of
Illinois
 United States Court of Appeals, Seventh Circuit
Education
 Juris Doctor, University of Illinois, 1985
 Bachelor of Arts-History (Summa Cum Laude),
Bradley University, 1982
Public Speaking
 “Elements of a Winning Workers’
Compensation Program”
Downstate Illinois Occupational Safety &
Health Day 2010
 “Family Medical Leave Act (FMLA); Americans
with Disabilities Act (ADA); and Workers’
Compensation”
Risk Control Workshop 2010
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Learn more about our speakers at www.heylroyster.com