In Morris v National Refractories & Minerals, 21 S.W.3d 886 (Mo.App. E.D. 2000), employer and insurer get credit for workers’ compensation payments for benefits made by the employee’s medical bills when the bills were paid by a third party instead of the employee’s health insurance. The third party is then reimbursed by the employer.

In Wilmeth v TMI, Inc., 26 S.W.3d 426 (Mo.App. S.D. 2000), the employer and the Second Injury Fund, neither one, are entitled to credit for amounts paid to claimant by the employer’s occupational health policy insurer, even though the employer pays 100% of the premiums. The Court held that the policy which paid the employee’s medical expenses was not a workers’ compensation policy. Accordingly, no credit.