This Note addresses the efficacy of construing the term "wages" RCW 51.08.178 to include employer-provided health insurance, hoping to serve as a resource for the Legislature to reevaluate IIA's wage definition in light of Cockle. First, this Note gives a general background of IIA and the Act's time-loss compensation scheme. Next, this Note discusses how Washington and other jurisdictions treat fringe benefits in defining "wages." This Note then examines the Washington Supreme Court's ground-breaking decision in Cockle, in which the court held that the value of employer-provided medical and dental benefits are part of the basis used to calculate workers' compensation payments. Finally, this Note analyzes the implications of Cockle and argues that the Legislature should narrow the Cockle court's interpretation of wages.
Matthew H. Adams, Cockle: Importing Health Benefits Into Wages—An Invitation for Legislative Review of the Wage Definition Under Washington's Industrial Insurance Act, 25 SEATTLE U. L. REV. 637 (2002).