The Pennsylvania Commonwealth Court has ruled that the employer who pays an injured employee wage loss benefits under the Heart and Lung Act is entitled to subrogate against the injured employee’s recovery against a negligent third party. In Oliver vs. City of Pittsburgh, the Court ruled that Heart and Lung Act benefits must be given the same effect as workers’ compensation benefits as the similar purpose of the two benefit schemes requires consistent treatment noting that benefits paid under the Heart and Lung Act should be treated in the same manner as payments made pursuant to the Workers’ Compensation Act. The Court concluded that the legislature intended the employer’s subrogation right entitlement to apply to Heart and Lung benefits as well as Workers’ Compensation benefits.