W000296

Saturday, November 10, 2001 8:10 AM
Fw: September 11 Victim Compensation Act Collateral Source Rule May Penalizes Diligence

Dear Mr. Zwick: Please carefully cosider the following comment:

September 11 Victim Compensation Act Collateral Source Rule Shouldn't Penalizes Diligence

The VCA collateral source rule requires that any award under the Act must be reduced by the amount of any "collateral source compensation" that "the claimant has received or is entitled to". VCA Section 405(b)(6).

The Act does not state that amounts received by VCF claimants from charities constitute "compensation", nor that a VCF claimant shall deemed "entitled to" any such amoumt, both within the meaning of VCA Section 405(b)(6). Therefore the Special Master should not reduce any compensation awarded under the Act, by the amount of any charity payment received by a VCF claimant regardless of whether or not actually received before application for or award under the Act.

There are also practical reasons for the Special Master not to treat charity receipts as collateral source compensation to be deducted from awards under the Act. Despite the best intentions, anyone who has diligently applied to any 9/11 charity for help well knows the uncertainty of many charities' criteria for making grants; seeming inconsistency in grant amounts among comparably situated applicants; and vast discrepancies between published grant criteria and the amounts of charity awards. In this enviroment, how can the Special Master possibly determine the amount of charitable awards to which a VCA claimant is "entitled" but which the claimant has not received or for which the claimant has not even applied at the time of filing a VCA claim or determination under the Act? Such a deduction would penalize the claimant who diligently applies for and receives charitable grants before filiing a VCA claim, as compared to a claimant who perhaps intentionally delays applying to any charity until after receiving payment from the Special Master.

If a major purpose of the Act is to encourage 9/11 victims to eschew the court system and rely upon the Special Master fairly to determine the amount of VCA compensation that a VCA claimant should receive, the amount of any charity receipt should be ignored in determining the compensation to which a VCA claimant is entitled.

For all these reasons, charity receipts should not be considered "collateral source compensation" under the VCA.

Respectfully submitted,

Individual Comment
Goshen, IN

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