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November 27, 2007

Massage Therapy Not Compensable Treatment

In this case, the Claimant provided a prescription from her treating physician for massage therapy treatment. The employer stipulated that the treatments were causally related to the Claimant's work injury. The Court found that a massage therapist is not a medical practitioner as defined in the Act. The Court noted that the massage therapist was not performing her services under referring physician’s supervision. The Court held that a doctor's prescription does not bring services within the definition of medical services. The Court reasoned that if an individual is not licensed or otherwise authorized to provide health care services in the Commonwealth, her services are not reimbursable under the Act. In the absence of a license, the provider's services are not reimbursable as services rendered by a health care provider. The Court concluded that should the Commonwealth issue state licensure for massage therapists, the outcome in future cases may be different. Until such time, employers are not required to pay for massage therapy treatment. 

What It Means to You

This is a rather significant development for carriers with claims in the Commonwealth Of Pennsylvania. The Commonwealth Court clearly states that massage therapy treatment is not reimbursable as services rendered by a health care provider under the Act. A note of caution is in order: before issuing a blanket denial of massage treatment. If the massage therapy is performed by a physical therapist or another individual capable of being licensed by the Commonwealth, it appears this treatment would be covered by the Act and therefore reimbursable. Contact a C&W workers’ compensation attorney to discuss your options when determining whether treatment is covered by the Worker’s Compensation Act.


2007 WL 2403720 (Pa. Cmwlth)