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Based on this decision, a Workers’ Compensation Judge has the exclusive jurisdiction to resolve disputes over Vouchers. More importantly, decision clarifies that an employer must make a “bona fide” offer of regular, modified, or alternative work to avoid liability for an Voucher, even to an inmate who had been released from his position previously held in prison. The inability to offer employment does not absolve an employer of the obligation to make a “bona fide” offer of employment.

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