Montana Self-Insurers Association CE Webinar
Ethical Communication with Treating Providers: Malcomson v. Liberty Northwest Ten Years Later
September 23, 2025 at 10a MDT.
Presented by W. Dean Blackaby of Montana Work Comp Solutions.
Advance Registration is Required by September 22.
Ethics credit for the MT Claims Examiner license has been approved. MSIA has applied for Ethics CE credit for the MT Insurance Producers* license through the CSI process. MSIA members have access to unlimited seats, all others are $25 each, with generous multiple seat discounts available by contacting MSIA. Advance registration is required by September 22.
This MSIA webinar will review the Malcomson decision – one of the landmark decisions by the Montana Supreme Court involving ex parte contact with a treating physician in a workers’ compensation claim. Malcomson is a question of third party communication with personal medical providers and the Montana Constitutional Right to Privacy. Blackaby will go through the decision, the Court’s reasoning and rationale as well as the impacts to the current Montana workers’ compensation system.
Malcomson remains the operative law regarding communication with treating physicians today.
W. Dean Blackaby is an attorney who has been active in the Montana workers’ compensation system since 1994. He started as a claims examiner for MSF, became a plaintiff attorney, then back to MSF as an in-house counsel, and then back to representing injured workers in the system. He has also developed an expertise in social security disability issues and Medicare Set Asides. All along the way, he has focused on providing training and education regardless of the side he has been representing. He is a leader who has been recognized within the state and nationally.
For Blackaby, Malcomson centered around the “Why?”
- Did you tell the Doctor my client called him a ‘quack’?
- Did this information help in generating a diagnosis?
- Did this information help the creation of a treatment plan?
- Did this information help the Identify the best medications and prescriptions?
- Did this information help the identify potential restrictions?
Using real and hypothetical examples, Blackaby explores the basis and the impact of the limitations on Ethical Communications with Treating Providers in the Montana workers’ compensation system. If you are doing work in Montana, if you have any relationship with the Montana workers’ compensation system, you don’t want to miss this important Webinar reviewing how we remain ethical, accountable and within the boundaries of our law.
Contact Carol LaFollette clafollette@medivest.com or (818) 730-8539
Contact Jere Kolstad at jerekolstad@clarusime.com or (406) 926-6950
Ethic credit has been approved for the MT WC Claims Examiner license and we have applied for Ethics CE credit for the MT Insurance Producers* license through the CSI process. MSIA members have access to unlimited seats, all others are $25 each, with generous multiple seat discounts available by contacting MSIA.
Advance registration is required by September 22.
*If you are seeking the MT Insurance Producer license credit, you must provide MSIA with your name as it appears on the license, your NPN number and your license number by Monday, September 22. Inaccurate or incomplete information will result in no credit being awarded.