Ostrawski v. Workers' Compensation Appeal Board (UPMC Braddock Hospital)

In determining whether a claimant is entitled to include wages earned with a concurrent employer in an average weekly wage the following factors should be examined: the period of employment preceding the work injury, whether periods of layoff were frequent, whether a concurrent employer terminated an employee during a layoff and whether a laid-off employee returned to work following such a period. Moreover, the Court explained that the presence of these factors can sufficiently demonstrate a pre-injury ability to earn wages for the alleged concurrent employment.