A.R.S. 23-1062(A) Interpretation
In Hughes v. Indus. Comm'n, 188 Ariz. 150, 933 P.2d 1218 (App. 1996), the Court considered a type of benefit similar to housekeeping services, and held that the claimant was not entitled to the benefit.
The claimant in that case argued that child care was "reasonably required other treatment" under A.R.S. 23-1062(A). 188 Ariz. at 152, 933 P.2d at 1220.
In rejecting the claimant's argument, the Court recognized:
Claimant concedes that child care generally is not medical treatment. However, she asserts that it should be classified as medical treatment when a doctor recommends it to relieve stress. the difficulty with this argument is that such a theory extends equally to any source of stress. a claimant may experience stress because he or she cannot care for an aging parent or disabled sibling, because he or she cannot meet financial obligations, or because he or she cannot perform a variety of domestic obligations. Id. at 154, 933 P.2d at 1222.