A practical, court-ready overview of how experts document and quantify changes in household services after an injury.
Why This Analysis Matters
Loss of household services is ultimately about change—what the individual contributed to the household before the injury versus what they can reasonably contribute after. A structured pre/post comparison creates a transparent record that supports objective valuation and avoids overstatement. (Standards vary by jurisdiction; this article is informational, not legal advice.)
Core Questions the Analysis Answers
- What tasks were performed pre-injury? (scope, frequency, and time)
- What capacity exists post-injury? (ability, efficiency, assistance needed)
- What is the measurable difference? (hours per week/month, seasonal swings)
- What portion reasonably requires paid replacement? (and for how long)
Step-By-Step Methodology
1) Establish the Pre-Injury Baseline
- Task Inventory: Identify specific tasks (e.g., weekly grocery run, daily meal prep, snow removal).
- Frequency & Duration: Estimate average time per occurrence; note daily/weekly/seasonal patterns.
- Role Context: Who else contributed? Were tasks shared or alternated (e.g., travel weeks)?
- Corroboration: Calendars, chore lists, sales receipts, vendor invoices, delivery logs.
2) Document the Post-Injury Reality
- Functional Limits: Pain, endurance, range of motion, restrictions, cognitive factors.
- Task Status: Stopped, reduced, modified, or requires assistance/supervision.
- Efficiency Loss: Tasks still completed but take longer or must be broken into shorter bouts.
- Substitutions: Paid vendors, family reassignment of tasks, assistive devices in use.
3) Quantify the Delta (Change)
- Hours Lost: Pre-injury hours minus post-injury hours (or added assistance time).
- Intensity & Safety: Differentiate light vs. moderate/heavy tasks (e.g., wiping counters vs. lifting snow blower).
- Seasonality: Adjust for weather-dependent or school-year tasks to avoid annualizing incorrectly.
- Ranges & Sensitivity: Use defensible ranges where variability is normal (e.g., 2–3 hours/week).
4) Align with Valuation (Economics)
- Replacement Cost: Map lost hours to market rates for comparable services (housekeeper, childcare, personal care aide, lawn service).
- Skill Level & Scheduling: Agency premiums, minimum visit fees, weekend/holiday rates.
- Duration: Temporary vs. long-term loss; recovery timeline if applicable (economist handles discounting/present value).
Scope discipline improves defensibility: the vocational expert establishes functional capacity and time, while the economic expert assigns dollar values.
Data Sources Experts Commonly Use
- Interviews: Individual + household members (to cross-check roles and time).
- Medical & Therapy Records: Functional Capacity Evaluations (FCE), PT/OT notes, physician restrictions.
- Daily Logs: Two-to-four-week time logs for current tasks and assistance needs.
- Digital Traces: Grocery delivery, rideshare, childcare apps, home-maintenance invoices.
- School & Care Schedules: For childcare/eldercare intensity and frequency.
Example (Illustrative Only)
- Pre-injury: Meal planning + grocery + cooking + cleanup ≈ 7.5 hrs/week
- Post-injury: Can prepare 2 light meals; grocery delivery added; spouse handles most cooking/cleanup → 3.0 hrs/week
- Delta: 4.5 hrs/week attributable to changed capacity/participation
- Next Step (Economics): Apply local replacement rates for shopping, meal prep, and cleanup, accounting for delivery fees and minimum service times.
(Actual figures depend on credible evidence, locality, and case specifics.)
Efficiency Loss vs. Task Substitution
- Efficiency Loss: Same task, more time (e.g., laundry now requires rest breaks). Count the incremental time.
- Task Substitution: Task moved to a paid vendor or another household member. If moved to a paid vendor, those hours typically map to replacement cost; if reallocated within the household, document the burden shift and whether paid replacement is still reasonable.
Building a Defensible Record: Attorney Checklist
- Pre-Injury Snapshot: Task list with frequency/duration; note seasonal items.
- Post-Injury Log: 2–4 weeks of real-time entries (who did what, how long, assistance).
- Corroboration File: Calendars, receipts, invoices, therapy notes, delivery histories.
- Vendor Quotes (if needed): Local housekeeping/childcare/personal care rates and minimums.
- Scope Boundaries: Keep vocational/time issues separate from economic/dollar issues in communications and reporting.
Common Pitfalls (and How to Avoid Them)
- Vague Descriptions: “Helps with kids” ≠ “Morning routine + school drop-off 5x/week (~50 min).”
- Double Counting: Don’t count the same block of time twice (e.g., laundry machine cycle while cooking).
- Ignoring Supervision Intensity: Infant/complex needs ≠ self-sufficient teen.
- Assuming Year-Round Equivalence: Snow removal and school logistics are seasonal.
- Role Drift: Pre-injury roles may already have been shared or variable—document reality, not assumptions.
Admissibility Considerations (High-Level)
- Transparency: Identify sources, assumptions, and calculations step-by-step.
- Method Consistency: Apply the same logic across tasks and time frames.
- Expert Roles: Maintain clear division between vocational (capacity/time) and economic (valuation).
- Jurisdictional Standards: Coordinate with counsel regarding local evidentiary rules (e.g., Daubert/Frye) and recoverability.
How KWVRS Approaches Pre/Post Analyses
- Neutral, Method-Driven Process: Structured inventories, corroborated time estimates, and clear documentation.
- Collaboration with Economists: Clean handoff from capacity/time findings to valuation.
- Court-Ready Reporting: Transparent sources, assumptions, and calculations suitable for deposition and trial.
Related Reading
- Loss of Household Services: Definitions, Scope, and Use in Litigation
- What Counts as Household Services? (categorizing tasks and documenting them)
Contact KWVRS
If your case involves potential changes in household roles post-injury, KWVRS can conduct a neutral, defensible pre/post contribution analysis and coordinate with forensic economists for valuation.
Contact us to discuss scope, documentation, and timelines.
