PA: Massage Therapy Provided by LPN Is Covered Medical Expense

A Pennsylvania appellate court recently held the cost of massage therapy services provided by a licensed practical nurse that had been prescribed by claimant’s treating physician must be paid by the employer or carrier since the LPN was a “health care provider” under the state’s Workers’ Compensation Act [77 Pa. Stat. Ann. § 29].  The court found that an earlier case, Boleratz v. WCAB (Airgas, Inc.), 932 A.2d 1014 (Pa. Cmwlth. 2007), where the therapist was not licensed as a health care provider, was not dispositive.

Reported by Thomas A. Robinson, J.D.

LexisNexis Online Subscribers: Citations below link to Lexis Advance. Bracketed citations link to lexis.com.

See Moran v. Workers’ Comp. Appeal Bd. (Flowers), 2013 Pa. Commw. LEXIS 421 (Oct. 16, 2013) [2013 Pa. Commw. LEXIS 421 (Oct. 16, 2013)]

See generally Larson’s Workers’ Compensation Law, § 94.03 [94.03]

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law.

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