Determining Whether Chiropractic Treatment After a Work Related Injury Is Unreasonable

In Jackson v. Workers' Comp. Appeal Bd. (Boeing), 825 A.2d 766 (Pa. Cmwlth. 2003), this Court concluded a Workers' Compensation Judge (WCJ) did not err in finding chiropractic treatment unreasonable and unnecessary. There, although the claimant's doctor testified the treatment he rendered reduced pain, swelling, and muscle spasms, the reviewer found the treatment unreasonable and unnecessary in part because the treatment, "although initially effective, is far less effective over time." Id. at 772. The WCJ accepted the opinion of the reviewer as more credible than that of claimant's doctor and concluded the treatment was unreasonable and unnecessary. The Court concluded such a credibility determination was binding on appeal.