On June 29, 2005 the Michigan Supreme Court dramatically changed the notice requirement for a certified vocationally disabled employee. Previously our courts had rigidly interpreted the notice requirement to mandate that the employer or insurance carrier must notify the Second Injury Fund “not less than 90 nor more than 150 days before the expiration of 52 weeks after the date of injury” as provided in Section 418.925. If an employer/carrier did notify the Second Injury Fund within this narrow window of 90 to 150 days prior to one year post injury, then the employer/carrier had no liability after one year post injury and all benefits after one year were paid by the Second Injury Fund. Conversely, case law previously established that if the employer/carrier failed to notify the Second Injury Fund within this narrow window of time, then the Second Injury Fund had no liability and the employer/carrier was responsible for the payment of benefits after 52 weeks. The Michigan Supreme Court in Bailey v Oakwood Hospital decided that the Second Injury Fund is responsible for the payment of benefits after 52 weeks even if the employer/carrier fails to provide notice to the Second Injury Fund within 90 to 150 days prior to one year post injury. There is no longer any situation where an employer/carrier can miss the deadline. Thus, any claim file that involves a vocational certificate and is being voluntarily paid should be reported to the Second Injury Fund and reimbursement obtained for all benefits paid after one year from the date of injury.