Requests for advances of $2,000.00 are all too familiar to workers’ compensation adjusters.   These advances are notoriously difficult to stop, so long as the Claimant can show a nexus between the advance and “medical and related financial needs arising from workplace injuries.”  ESIS/ACE Am. Ins. Co. v. Kuhn, 104 So.3d 1111, 1114-15 (Fla 1st DCA, 2002).

The First District has recently clarified this standard through its decision in Bonner v. Miami Dade County School Board, Fla 1st DCA, Case No. 1D14-1200, specifying that the JCC’s nexus inquiry should not consider whether the Claimant was poorly managing her finances or spending on luxury items.    Instead, the First District specified that the only criteria for addressing the advance should be whether the financial needs arose from the work-related accident.  In short, even if a Claimant were paying for an ongoing Netflix subscription, it would not be relevant to the advance so long as he can demonstrate a nexus between his financial need and the accident.