(Under Section 287.170, the limited for which the employee can recover this type of disability benefit is 400 weeks of such disability. From a practical standpoint the employee will normally convert that to a permanent total award, which has no cap.)
In Richey v Schnucks Markets, (LIRC), 1/17/01, ( ALJ Dierkes), Claimant found at MMI despite subsequent surgeries for back and hardware removal. The Commission reverses and awards credit for overpaid TTD by employer, but increased PPD from 40% to 55% for 4 level fusion.
In Shaw v Scott, 49 S.W.3d 72 (Mo.App. W.D. 2001) Commission can double the amount of TTD award if the employer does not pay it was on appeal to the Commission.
In Boyles v U.S.A. Rebar Placement, Inc., 26 S.W.3d 418 (Mo.App. W.D. 2000). Iron worker had severe back injury, released with permanent work restrictions which did not allow him to return to his job as an iron worker, in which lifting restrictions the employer could not accommodate. The employer, however, paid TTD during the entire treatment, even though the treatment continued after he was placed a MMI. After discharge from treatment, he requested surgery, got it, was paid TTD during the period of recovery.