I have had a couple of clients contact me and send materials relating to the PG&E bankruptcy. Normally when an insurance carrier goes into liquidation, all the workers compensation files are taken over by the California Insurance Guarantee Association, CIGA, which was founded some years ago to address a crisis in failed workers compensation insurance carriers. CIGA is considered a payer of last resort, so most of the litigation involving CIGA is related to whether or not someone else should pay. A recent case in the Ninth Circuit was reversed this month California Ins. Guar. Ass’n v. Azar, 2019 U.S. App. 30339 (9th Cir. Oct. 10, 2019)] saying CIGA is not required to reimburse Medicare for payment made on behalf on injured workers. How does this related to PG&E, a permissibly self insured (PSI) entity? For self insured employers California has established the Self Insurer’s Security Fund. Just like CIGA the fund takes over when a PSI goes into liquidation. The benefits provided are exactly the same and the workers compensation statutes and regulations apply. About the only change is that the files may sent to another defense firm for handling. Let us hope the Self Insurer’s Security Fund is more responsive and willing to settle out PG&E cases than was PG&E.