Cummings v. Twin Tool Mfg. Co

In Cummings v. Twin Tool Mfg. Co., 40 Conn. App. 36, 38 n.1, 668 A.2d 1346 (1996), the Court held that the commissioner had the authority to order out-of-state medical treatment. Id., 256-57. The Court remanded the case, however, so that the commissioner could conduct an evidentiary hearing to determine whether the claimant, who was a resident of Connecticut, could receive equally beneficial treatment in Connecticut. "It is well settled that the legislature's longstanding policy has been that our Workers' Compensation Act . . . is remedial in nature and should be broadly construed to accomplish its humanitarian purpose." The compensation review division has construed the Workers' Compensation Act "to permit out of state treatment when there is good reason, such as the need for a specialized type of treatment . . . or under other proper circumstances . . . ." Id., citing J. Asselin, Connecticut Workers' Compensation Practice Manual (1985) p. 183 n.329. Good reason exists for out-of-state medical treatment when the treatment is reasonable and necessary. Cummings v. Twin Mfg., Inc., supra, 259.