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When Remote Work Crosses State Lines: What California Education Employers Need to Know About Workers’ Compensation

Remote work has expanded the talent pool for California educational employers, allowing school districts and county offices of education to recruit skilled professionals regardless of where they live. From technology and finance specialists to human resources and special education professionals, organizations are increasingly considering candidates who work outside California.

However, a recent California Workers’ Compensation Appeals Board (WCAB) decision highlights an important consideration for employers navigating these arrangements: workers’ compensation obligations do not automatically follow the employer's headquarters location.

A closer look at the Danzey decision

In Danzey v. Aravo Solutions, Inc., the WCAB examined whether California had jurisdiction over a workers’ compensation claim filed by an employee who lived and worked exclusively in Florida for a California-based company.

The employee resided in Florida, performed all job duties there, and accepted and signed her employment agreement while in Florida. Although the employer was incorporated and headquartered in California, the WCAB concluded that these facts alone were insufficient to establish California workers’ compensation jurisdiction.

The Board also confirmed that a California choice-of-law provision in an employment agreement cannot create workers’ compensation jurisdiction when statutory jurisdiction does not otherwise exist.

While Danzey is a panel decision and not binding precedent, it provides valuable insight into how jurisdictional questions may be evaluated when employees work remotely outside California.

Why this matters for public education employers

As remote and hybrid work arrangements become more common, California educational employers face new compliance considerations. When an employee works primarily outside California, employers should not assume that California workers’ compensation coverage fully addresses their obligations.

Workers’ compensation requirements are often tied to where the employee performs their work. As a result, another state may require separate coverage, reporting, or compliance under its own workers’ compensation laws.

For districts participating in the Protected Insurance Program for Schools (PIPS) Workers’ Compensation JPA, as well as permissibly self-insured employers that purchase Excess Workers’ Compensation Insurance, this distinction is particularly important. While these programs are designed to address California workers’ compensation obligations, an employee working permanently in another state may create exposures under that state's workers’ compensation system.

When to review your workers’ compensation obligations

Employers should carefully evaluate workers’ compensation implications whenever an employee:

• Is hired to work remotely from another state.
• Relocates outside California while remaining employed.
• Performs ongoing job duties on a regular basis outside California.

Each situation presents unique considerations, but the common question remains the same: Does the employee's state of residence and work create workers’ compensation obligations that extend beyond California?

Addressing these questions early can help employers avoid coverage gaps, compliance challenges, and jurisdictional disputes should a workplace injury occur.

Taking a proactive approach

As organizations continue to embrace workplace flexibility, it is critical to review insurance and risk management implications alongside operational and staffing decisions.

Districts with employees who work permanently outside California should work with their Keenan Account Manager to evaluate their current workers’ compensation program and determine whether additional coverage or compliance measures may be necessary.

Proactive planning can help ensure injured employees have access to benefits when needed while protecting the organization from unexpected liabilities and administrative complications.

Key takeaway

The Danzey decision reinforces a straightforward but important principle: where employees live and perform their work matters.

For California educational employers, remote work arrangements that extend beyond state lines may trigger workers’ compensation obligations outside California, even when the organization itself is based within the state. By evaluating workers’ compensation requirements before approving or continuing out-of-state remote work arrangements, employers can better safeguard their employees, maintain compliance, and reduce the risk of costly coverage disputes in the future.

This article is based on and adapted from research published by Sullivan Attorneys LLP in “WCAB Clarifies Jurisdiction for Out-of-State Remote Workers,” discussing Danzey v. Aravo Solutions, Inc. (2026).