August 25, 2026

What happens when an injured employee alleges that they have sustained lost or broken teeth? Under Pennsylvania workers’ compensation law, an employee may recover specific loss benefits for disfigurement resulting from dental injuries. Whether an employee is entitled to these benefits is determined by a Workers’ Compensation Judge (WCJ), who may consider:

1. The permanence of the condition;
2. The nature of the dental restoration;
3. Whether the restoration is permanent or removable; and
4. The claimant’s appearance without removable prosthetics.

Orthodontists and dental physicians can provide dentures and other dental restorations that may be difficult or impossible to discern. Despite this, a WCJ may still award specific loss benefits even when a claimant’s teeth have been repaired. The WCJ may also evaluate whether the dental restoration is permanent or removable.

What Qualifies as a Serious and Permanent Disfigurement in Pennsylvania?

Under Section 306(c)(22) of the Pennsylvania Workers’ Compensation Act, a claimant is entitled to specific loss benefits for “serious and permanent disfigurement of the head, neck or face, of such a character as to produce an unsightly appearance, and such as is not usually incident to the employment.” 77 P.S. § 513.

When a disfigurement claim involves missing teeth, the WCJ must evaluate the claimant without any removable prosthesis, such as dentures, to get a true picture of the unsightly appearance the claimant experiences when not wearing the prosthesis. Agnello v. Workers’ Comp. Appeal Bd. (Owens-Illinois), 907 A.2d 676 (Pa. Cmwlth. 2006).

Pennsylvania courts have explicitly recognized that the loss or damage of natural teeth resulting from a work-related injury can constitute serious and permanent disfigurement of the face. Disfigurement may remain compensable even if the claimant’s teeth are repaired or replaced with prosthetics, such as bridges or dentures.

Can Dental Repairs Eliminate a Disfigurement Claim?

In School District of Philadelphia v. Workmen’s Compensation Appeal Board (Gardiner), 98 Pa. Commw. 580, 511 A.2d 947 (Pa. Cmwlth. 1986), the claimant lost teeth as a result of a work-related injury and had them replaced with a bridge. The WCJ nevertheless awarded disfigurement benefits.

The court explained that the claimant’s previous appearance could properly be considered, but that such a comparison was not indispensable to an award of benefits. The court further found that the presence of a bridge did not eliminate the claimant’s disfigurement altogether, but instead diminished its effect.

Accordingly, a claimant may still have a viable claim for disfigurement benefits even after lost or damaged teeth have been “fixed.”

Can Permanent Dental Implants Affect a Disfigurement Claim?

The timing and permanence of dental treatment can also be significant. In Frank v. Workers’ Comp. Appeal Bd. (Southampton Tire), 2018 Pa. Commw. Unpub. LEXIS 627 (2018), the Commonwealth Court distinguished cases involving permanent dental implants.

Where a claimant is able to schedule permanent implants that will permanently address the tooth disfigurement, it may be premature to ask a WCJ to evaluate the damage before the permanent implant work is completed.

Thus, the type of dental restoration can be an important consideration in determining whether a claimant is entitled to specific loss benefits.

What Should Employers and Insurers Consider When Evaluating a Dental Injury Claim?

When evaluating a claim involving lost or broken teeth, employers and insurers should consider:

1. The nature of the injury: Whether the claimant has lost or damaged natural teeth.
2. The claimant’s appearance: A WCJ may evaluate the claimant without removable prosthetics.
3. The type of dental restoration: Bridges, dentures, implants, and other restorations may be treated differently.
4. The permanence of the restoration: Permanent implants may affect whether it is appropriate to evaluate the disfigurement before treatment is completed.
5. The individual facts of the case: The WCJ has the authority to determine whether the condition constitutes a compensable disfigurement and the value of the specific loss claim.

Are Repaired or Replaced Teeth Still Eligible for Disfigurement Benefits?

The fact that a claimant’s teeth have been repaired or replaced does not necessarily eliminate a claim for specific loss benefits based on disfigurement. At the same time, permanent dental implants or other permanent restorations may affect the outcome.

As with any disfigurement claim, each case turns on its particular facts, and the WCJ has significant discretion in evaluating the nature and permanence of the condition and determining the appropriate value of the claim.

If you have questions about Pennsylvania workers’ compensation claims involving dental injuries or other workers’ compensation matters, please contact Bret R. Goldstein, Chair of RRD’s Workers’ Compensation Practice Group, at bgoldstein@regerlaw.com or 215-495-6528.