Does Ohio Workers’ Compensation Cover Mental Health Claims?

The concept of a “workplace injury” typically brings to mind physical ailments such as a strained back, broken bones, concussions, repetitive use injuries, and burns. But there’s growing recognition of the mental health challenges workers face on the job—and the growing need to provide workers’ compensation mental health benefits.

Conditions like anxiety, burnout, and post-traumatic stress disorder (PTSD) are becoming part of mainstream conversations, and the U.S. healthcare system is adopting a holistic approach that considers the individual’s overall well-being and the connection between physical and mental health.

In many states, however, including Ohio, the workers’ compensation system lags behind. These “invisible” injuries, though just as real and disabling as physical ones, are harder to prove and rarely covered unless strict conditions are met. And even in valid mental health cases, Ohio workers may find themselves in a legal fight to get the workers’ compensation benefits they deserve.

The Growing Mental Health Crisis Among Workers

The mental health burden among American workers has become impossible to ignore, and Ohio is no exception. Across industries, employees report rising rates of psychological distress, emotional exhaustion, and trauma linked directly to the workplace. Mental health disorders now cause more work absence and work disability than musculoskeletal problems.

Each year, around 1 in 5 Americans experiences a diagnosable mental health condition, and nearly 50% will at some point in their lives. More than 40 million Americans live with anxiety disorders, 22.5 million deal with depression, and 6% will develop PTSD.

Ohio has historically taken a narrow view of compensable mental health conditions.

Although work can provide structure and escape from personal challenges, it’s often a major source of stress itself. Burnout, while not officially a mental health diagnosis, can lead to depression, anxiety, and other clinical disorders. A recent Gallup survey revealed 3 out of 4 employees feel burned out at least occasionally. In 2025, job burnout reached 66%, according to one study. The APA’s latest Work in America survey echoed these findings, noting over 20% of U.S. workers report poor or fair mental health.

In Ohio and elsewhere, the outlook is especially troubling in high-stress sectors like healthcare and emergency response.

Healthcare consistently ranks among the most burned-out professions. Workers in ERs, ICUs, or those caring for assault victims develop PTSD at nearly double the rate of the general population due to exposure to trauma in the line of duty. Ohio has approximately 300,000 licensed nurses and related health professionals. Of these, nearly 21% may meet the criteria for a clinical PTSD diagnosis.

Emergency responders face comparable on-the-job risks. Long shifts, sleep deprivation, and routine exposure to disturbing incidents put Ohio’s approximately 1 million law enforcement personnel and 50,000 certified EMS and fire personnel at elevated risk of burnout and PTSD. Depression and PTSD are 5 times more common among first responders than in the general population.

But no job is immune from mental health triggers. For example:

• Teachers may witness violence at school. A meta-analysis of five studies found an estimated overall prevalence of PTSD in teachers at 11%.
• Manufacturing workers can see serious accidents. A study published by the journal Social Psychiatry and Psychiatric Epidemiology showed that mental health issues are 36% more prevalent in manufacturing employees than the national average.
• Carpenters, cooks, laborers, construction workers, coal miners, and personal services workers are among the professions associated with elevated risks of developing psychological distress.

Workers who do not directly witness trauma, but work in high-stress environments, like 911 dispatchers, can be at risk for developing anxiety, depression, and PTSD as well. Even call center employees dealing with abusive customers, long hours, and hostile supervisors can develop occupational PTSD.

Ohio’s Workers’ Compensation and Mental Health Claims – A Work in Progress

Mental health is no longer a fringe issue. Employers now recognize it as central to workplace safety, productivity, and employee retention. But Ohio’s workers’ compensation laws haven’t fully caught up.

Historically, Ohio has taken a narrow view of compensable mental health conditions. Claims for anxiety, PTSD, or depression were largely excluded unless linked directly to a physical injury. This means workers suffering emotional trauma without physical harm (say, from witnessing a violent accident or enduring chronic workplace abuse) are generally ineligible for benefits.

In 2021, Ohio passed a law permitting first responders—police officers, firefighters, and EMTs—to claim benefits for PTSD caused by traumatic work events, without a physical injury. These claims are handled outside the standard Bureau of Workers’ Compensation system but offer similar financial and medical protections.

This carveout, unfortunately, is limited and does not extend to other workers or to mental health conditions not tied to physical injuries.

Currently, Ohio workers’ compensation mental health claims are only covered only in limited scenarios:

• Physical-Mental Claims: When a mental health condition like depression or anxiety arises as a direct consequence of a physical workplace injury or occupational disease, it may be compensable. For example, a worker who suffers a serious injury and subsequently develops depression linked to chronic pain could qualify.
• PTSD for First Responders: First responders diagnosed with PTSD tied to a work-related traumatic event can seek benefits under the 2021 law, without needing a physical injury.

Other workers generally cannot claim so-called “mental-mental” injuries (claims based solely on psychological trauma). The Ohio Revised Code continues to require a physical injury component, with the sole exception of first responder PTSD.

A notable case that underscores the challenges most Ohio workers face when pursuing mental health claims is Armstrong v. John R. Jurgensen Co.

In this case, dump truck driver Shaun Armstrong was involved in a severe rear-end collision during his employment. The accident resulted in minor physical injuries for Armstrong but killed another driver. He later developed PTSD, experiencing nightmares and panic attacks. His physical injury claim was approved, but his PTSD claim was denied.

The court ruled that Armstrong’s PTSD stemmed from the emotional trauma of the fatal accident, not from his physical injuries. Because Ohio law demands a direct link between a psychiatric condition and a physical injury (outside of the first responder exception), his mental health claim was not compensable.

The Ohio Supreme Court upheld this interpretation, which underscores how narrowly Ohio law is drawn—and how mental health claims often fall through the cracks. The court concluded that “a psychiatric condition is not a workers’ compensation injury except when the condition has arisen from an injury or occupational disease sustained by that claimant.”

The Complicated Process of Filing an Ohio Workers’ Comp Mental Health Claim

If a worker’s mental health condition stems from a workplace incident and meets Ohio’s narrow eligibility standards, they may still face a complex, and sometimes adversarial, process.

Their employer or the Bureau of Workers’ Compensation (BWC) might challenge these “invisible injuries” and blame mental health conditions on personal life stress, prior trauma, or unrelated medical history.

Then there’s the complicated paperwork that must be filed, accurately and on time, to support a claim. Errors, omissions, or delays can derail a claim entirely.

It’s “okay” to not be “okay.” It’s also okay to ask for help from an Ohio workers’ compensation attorney.

Necessary forms, such as C-86, used when a worker wants to add a mental health diagnosis to an existing claim (e.g., after a physical injury), could be heavily scrutinized. For psychiatric or psychological conditions, Form C-86 requires a signed statement from the injured worker acknowledging their mental condition is a result of the work-related injury, along with supporting documentation, including medical reports, physician statements, and diagnostic test results.

If the BWC denies the request for an additional mental health allowance, a hearing at the Industrial Commission may follow, where the claim can be approved, denied, or pushed back. A denied claim may need to be appealed to a state court, and sometimes, it is necessary to appeal a claim at multiple levels.

When Injuries Are More Than Meets the Eye, You Need Graham Law

Mental health injuries like anxiety, burnout, and PTSD may be harder to see than physical injuries, but for the workers suffering from them, they are readily apparent. They may also qualify Ohio workers’ compensation, but because state law still treats them with skepticism, workers could face an uphill battle to get their mental health claim approved.

A frequent mental health refrain is that it’s “okay to not be okay.” It’s also okay to ask for help when you need it, and that includes help from a workers’ compensation attorney at Graham Law. We assist at all stages of the workers’ comp process, from filing an initial claim to Industrial Commission and court appeals.

Email David Graham or contact our Zanesville office) to schedule a free case review.