Can You Get Reimbursed for Unlicensed Health Care Providers Services ?
In Taylor v. Workers' Compensation Appeal Board (Bethlehem Area School District), 898 A.2d 51 (Pa. Cmwlth. 2006), the Court held that a vocational expert's lack of professional licensure by the Commonwealth meant that the employer did not have to pay his bills, despite the fact that the claimant's physician wrote a prescription for vocational expert services.
The Court explained:
In order to be reimbursable under Section 306(f.1)(1) of the Act, "medical services" must be rendered by a duly licensed medical practitioner, even if there is no licensing program for that medical specialty.
For example, even though the Commonwealth has no licensing program for psychotherapy, such practice is considered "medical services" and reimbursable under the Act when administered by a duly licensed practitioner or under the supervision of such a person. Foyle v. Workmen's Compensation Appeal Board (Liquid Carbonic I/M Corp.), 160 Pa. Cmwlth. 534, 635 A.2d 687, 691 (1993) (finding psychotherapy services rendered by a doctor of education, an unlicensed professional, not reimbursable);
See also Morwald v. Workmen's Compensation Appeal Board (Eng'g & Refrigeration, Inc.), 143 Pa. Cmwlth. 511, 599 A.2d 307, 308-09 (1991) (reasoning that psychotherapy is reimbursable as a medical service because licensed psychologists or psychiatrists generally conduct psychotherapy.
The Court explained further that a doctor's prescription does not bring services within the definition of medical services.
Quite simply, if an individual "is not licensed or otherwise authorized to provide health care services in the Commonwealth, ... his services are not reimbursable under the Act." Id. at 54.
In the absence of a license, the provider's services are not reimbursable as services rendered by a health care provider under the Act.