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A Pennsylvania appellate court held it was error for the state’s Workers' Compensation Appeal Board to find that a claimant’s massage therapy expenses were not reimbursable where they were provided by a massage therapist under the supervision of claimant's licensed chiropractor under 77 Pa. Stat. Ann. § 531(1)(i). While the massage therapist was not a “health care provider” as that term is defined by the Pennsylvania Workers' Compensation Act, the services were being provided under the supervision of the chiropractor, who was such a “health care provider.”
Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is the co-author of Larson’s Workers’ Compensation Law (LexisNexis).
LexisNexis Online Subscribers: Citations below link to Lexis Advance.
See Schriver v. Workers’ Comp. Appeal Bd., 2017 Pa. Commw. LEXIS 1084 (Dec. 28, 2017)
See generally Larson’s Workers’ Compensation Law, § 94.03.
Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law