Can You Be Reimbursed for Psychotherapy by An Unlicensed Therapist ?
In Morwald v. Workmen's Compensation Appeal Board (Engineering & Refrigeration, Inc.), 143 Pa. Commw. 511, 599 A.2d 307 (Pa. Cmwlth. 1991), the claimant sought reimbursement for medical fees associated with psychotherapy he received from an unlicensed therapist.
The Workers' Compensation Judge (WCJ) denied reimbursement, finding that the claimant's psychotherapy was not rendered by a duly licensed practitioner of the healing arts, and, therefore, was not reimbursable under the Act.
The Workers' Compensation Appeal Board (WCAB) affirmed.
On appeal to this court, we affirmed on other grounds.
The Court determined that psychotherapy is a medical service, not a separate healing art, and, therefore, the cost of properly prescribed psychotherapy is recoverable under the Act even though the Commonwealth does not provide licensure to psychotherapists.
The Court also recognized that the claimant's therapist may have been qualified to provide psychotherapy according to a regimen prescribed by a healing arts practitioner whose license includes diagnostic and prescriptive functions.
Nevertheless, the Court agreed that the cost of the claimant's psychotherapy was not recoverable, stating that "without supervision by, or at a minimum, a referral from, such a practitioner, the psychotherapy rendered ... does not come within the provisions of then 306(f) of the Act." Id. at 309.