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Tennessee: No Subrogation Lien for Nurse Case Management Expenses

February 21, 2019 (1 min read)

A Tennessee employer’s subrogation lien does not include expenses related to nurse case management, held a Tennessee appellate court. Observing that the management services tended to benefit the employer, not the employee, the Court was also unconvinced by the employer’s argument that such expenses should be recoverable since case management was mandatory in the state. Acknowledging further that the case was one of first impression in the Volunteer State, the Court looked to an Illinois decision in which the cost of services for a “medical rehabilitation coordinator” had been excluded from the subrogation amount. The facts here were similar, said the Tennessee court.

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance.

See Memphis Light Gas & Water Div. v. Watson, 2019 Tenn. App. LEXIS 82 (Feb. 13, 2019)

See generally Larson’s Workers’ Compensation Law, § 117.03.

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

For a more detailed discussion of the case, see