Selective Insurance Company of America v. State of New York Workers' Compensation Board
Petitioners, a group of insurance carriers, challenged the Workers’ Compensation Board’s refusal to issue them a credit or refund for assessments paid in excess of surcharges collected from their policyholders between 2001 and 2009. This discrepancy arose due to different methodologies used to calculate assessments (by the Board based on "total written premiums") and surcharges (by carriers based on "standard premiums"), resulting in some carriers collecting more in surcharges (windfall carriers) and others paying more in assessments (shortfall carriers), like the petitioners. In 2009, the Legislature amended the Workers’ Compensation Law to align the assessment methodology with "standard premiums" and authorized the Board to collect excess funds from windfall carriers. The amendment also allowed the Board to issue credits or refunds for "overpayments made to the fund." Petitioners interpreted this as applicable to shortfall carriers, but the Board denied their request, contending "overpayments" referred only to those made by windfall carriers. The court affirmed the Board's determination, finding its interpretation rational and consistent with the legislative intent, which was focused on deficit reduction and did not provide for relief to shortfall carriers.