Carr v. Industrial Commission of Arizona
In Carr v. Industrial Commission of Arizona, 197 Ariz. 164, 167,12, 3 P.3d 1084, 1087 (App. 1999), however, we held a worker may be entitled to reimbursement for travel expenses incurred in obtaining medical treatment "outside the area in which he or she resides."
In that case, the closest place the claimant could obtain physical therapy for his industrial injury was a 230-mile round trip from his home, and the ALJ found he could not afford to travel that distance. Id. at 165-66,4-5, 3 P.2d at 1085-86.
Carr reasoned that, under the circumstances, denying the claimant's request for reimbursement of travel expenses "effectively denied him the medical treatment to which he had a right under our workers' compensation law." Id. at 166-67,7, 12, 3 P.2d at 1086-87.
The Court concluded that although 23-1062(A) does not expressly define "medical benefits" to include travel expenses, "an injured worker who must travel outside the area in which he or she resides to receive treatment is entitled to reimbursement for travel expenses." Id. at 166-67,10, 12, 3 P.2d at 1086-87.