Determining Whether Physical Therapy After a Work Related Injury Is Unreasonable
In Haynes v. Workers' Comp. Appeal Bd. (City of Chester), 833 A.2d 1186 (Pa. Cmwlth. 2003), the Court considered whether a finding that physical therapy was unreasonable and unnecessary was error.
The Court concluded it was not where, "the Workers' Compensation Judge (WCJ) finding that the physical therapy was unreasonable and unnecessary was based not on its palliative nature, but on his acceptance of the opinions ... that the program was repetitive, did not require skilled care, and was incomplete ...." Id. at 1191.