January 15, 2026

When a workers’ compensation Claimant dies from causes unrelated to the work injury, indemnity benefits generally terminate as of the date of death. This result is consistent with Section 306(a) of the Pennsylvania Workers’ Compensation Act, which provides that both total and partial disability benefits end upon a Claimant’s death. Section 306.

Exception – Specific Loss Benefits

The primary exception to this rule arises under Section 306(g) of the Act, which permits payment of Specific Loss Benefits under Section 306(c)(1–25) to a Claimant’s dependents or, if none exist, to the Claimant’s estate.

Under 77 P.S. § 751, if a Claimant dies before final adjudication of a claim for specific loss arising from a work-related injury, compensation due through the date of death is payable to dependents entitled to compensation, or to the estate if there are no dependents.

In Steets v. Celebration Fireworks, Inc. (Workers’ Comp. Appeal Bd.), 335 A.3d 1076 (Pa. Cmwlth. 2025), the Court reaffirmed this limited exception. Notably, in Steets, Specific Loss Benefits had been awarded and were under appeal by the employer at the time the Claimant died from work-related causes.

Best Practices for Employers and Insurers

1. Upon learning of a Claimant’s non-work-related death, and where no potential Specific Loss Benefits exist, issue Form LIBC-751 (Notification of Suspension or Modification) immediately.
2. Once the non-work-related cause of death is factually established, issue a Final Receipt (Form LIBC-340).
3. If a Claimant dies from work-related causes, anticipate the filing of a Fatal Claim Petition.
4. If Specific Loss Benefits are being litigated or appealed at the time of a Claimant’s death from work-related causes, dependents or the estate may recover those benefits if ultimately awarded.

If you would like more information or need assistance with Workers’ Compensation matters, please contact Bret R. Goldstein at bgoldstein@regerlaw.com or 215-495-6500.