The Supreme Court of Pennsylvania held that a claimant must prove a change in his or her physical condition only in cases where the employer would have to prove the same.
Dillon v. Workmen's Compensation Appeal Board (Greenwich Colliers), 640 A.2d 386 (Pa. 1994).
William B. Pentecost Jr.,
Workers' Compensation - Physical Condition - Disability - Claimant's Burden of Proof,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol33/iss3/14