Workers’ Compensation Claims: Laying the Groundwork for Successful Subrogation

WCI 2026 Platinum Sponsor Article | Presented by CCMSI

Brian L. Poust, Esq. | Vice President

A subrogation investigation is more than a routine step in the workers’ compensation process; it’s a strategic and financial necessity. Promptly identifying third-party liability and aggressively pursuing recovery can significantly reduce claim costs, improve loss history, and deliver overall better claim outcomes.

From Identification to Action
Effective subrogation begins with early intervention. Quickly detecting third-party involvement, whether a product, contractor, property owner, or medical provider, lays the groundwork for recovery. At the same time, flagging roadblocks early (e.g., waiver agreements) avoids chasing non-viable claims. Promptly notifying potentially liable third parties and governmental entities, when applicable, protects recovery rights. Delays cost more than just time; they can eliminate recovery altogether.

Establishing Third-Party Liability
Identifying responsible parties and developing a clear theory of liability (e.g., premises, general negligence, medical malpractice, and product liability) is vital to successful subrogation. It is essential to determine whether a third party, such as a manufacturer, landlord, or public entity, breached a duty of care that led to the injury.

Premises Liability: Claims involving injuries on another’s property require clear and thorough documentation of the hazardous condition. In slip-and-fall claims, recovery often hinges on proving that the property owner knew or should have known about the danger and failed to address it within a reasonable timeframe. Gather evidence on how long the condition existed and whether the property owner had notice.
Automobile Accidents: Assess whether all parties maintained a proper lookout, followed traffic laws, and whether road conditions contributed to the accident. Determining the right-of-way and reviewing any police reports or traffic citations can offer valuable insight into liability.
Medical Malpractice: If medical care worsens an injury or causes new complications, evaluate if the provider acted within the accepted standard of care. While not all errors in judgment constitute malpractice, deviations from established protocols or failures to prevent foreseeable complications may support a subrogation claim. Specialists, held to a higher degree of care, often present more challenging cases.
Product Liability: Product liability claims often require more detailed and costly investigations, making cost-benefit analyses beneficial. Claims typically stem from design or manufacturing defects, or failures to warn of dangers or provide instructions for safe use. Investigate by securing the product, interviewing the operator, identifying the manufacturer, obtaining purchase records, and consulting experts. Confirming the defect and its role in the injury is critical to recovery.
Construction Injuries: In construction claims, determine all involved contractors and review indemnification agreements. Secure contracts, statements, and official reports (e.g., OSHA, police). As with all subrogation cases, document the conditions that caused the loss and evaluate legal defenses, such as waiver agreements or statutory employer defenses.

Core Components for Subrogation Success
Effective recovery requires a well-executed and thorough investigation, careful assessment, and strategic prosecution. Each claim is unique, requiring a tailored approach based on the specific facts and circumstances.

Witness Statements and Photographs: Witness testimony is invaluable, but delays risk losing vital details to fading memories or outside influence. Quickly gather photos and Q&A-style written, recorded, or video statements. Documenting witness information will be necessary if it is needed for later testimony.
Preserving Evidence: Preserve evidence (e.g., photos, condition reports, and contracts) in their original form to avoid loss, damage, or spoliation claims that can undermine recovery. Do not conduct destructive testing without proper consent and notify all parties before inspections.
Documenting the Scene and Gathering Supporting Evidence: Detailed measurements, diagrams, and preserving the scene layout help establish liability and clarify event sequences. Supporting documents, including contracts, police reports, inspection records, and weather data, provide context and objective evidence to support the claim.
Engaging Experts: While not all claims require expert testimony, complex cases, such as product liability or medical malpractice, may benefit from expert analysis. When engaging experts, outline clear expectations but avoid requesting written reports until needed for litigation.
Ensuring Legal Readiness and Compliance: Effective third-party recovery requires more than identifying a responsible party; in some cases, it demands timely legal action. Prompt notice, especially to governmental entities, is critical to preserving subrogation rights. When warranted, counsel can help navigate complex issues and strengthen the case. Reviewing laws, codes, and ordinances, and confirming applicable statutes of limitations, ensures legal readiness.

Every step matters, from identification through litigation. Successful recovery demands experienced claim professionals, a proactive approach, and collaboration. CCMSI’s Subrogation Unit combines centralized coordination with industry expertise to rapidly detect opportunities, streamline the recovery process, and reduce overall claim costs.

Brian L. Poust
About the Author

Brian L. Poust, Esq.

Vice President

Professional Experience

With over three decades of experience in the insurance industry, Mr. Poust is a vice president at Cannon Cochran Management Services, Inc. (CCMSI), working closely with clients, brokers, carriers, legal counsel, and CCMSI staff to ensure timely investigation, negotiation, and claim resolution.

Before joining CCMSI in 2004, Mr. Poust built a foundation in the industry as an adjuster at Aetna Life and Casualty, managing workers’ compensation and commercial general liability claims for national accounts, including JA Jones, Peter Kiewit, and Morrison Knudsen. Following several promotions, he transitioned into the legal field, earning a Juris Doctor from the University of Illinois College of Law in 1993. Mr. Poust practiced law as a defense attorney at the prominent Chicago law firm Cassiday Schade LLP, specializing in construction litigation, coverage, and product liability. His legal expertise and claims management knowledge provided a unique advantage when he returned to the insurance industry.

His career continued to evolve as he joined third-party administrator McLarens Toplis, and then Ward North America, supervising adjusters and managing claims. Throughout his career, Mr. Poust has gained extensive experience working with public entities, a diverse range of carriers, self-insured clients, and the London market. Combining his insurance expertise, legal knowledge, and client-focused approach, Mr. Poust is a respected leader at CCMSI, driving successful outcomes for clients and ensuring their claims are handled efficiently and professionally.

Education and Professional Training

Mr. Poust graduated as salutatorian from Blackburn College in 1987 with a degree in Business Administration and a minor in Economics, and later with honors from the University of Illinois College of Law in 1993. He attended Aetna Life and Casualty’s Claims School in 1987 and has completed several courses through the Chicago Insurance Institute.

CCMSI: Mitigating losses and maximizing recovery for our clients since 1978.