The commercial rate is the appropriate measure for gratuitous care even where a family member provides the care, following Van Gervan v Fenton and Kars v Kars. The administration component of a daily care rate may be disallowed for periods where a family member is providing care without engaging a commercial provider. Social security payments received must be taken into account when calculating interest on past economic loss. In assessing future economic loss, assumptions of virtually continuous employment must be justified by pre-accident performance and must account for realistic contingencies including the economic conditions of the plaintiff's locality.
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