How to Prove Duplicate Medical Payments to Providers ?
In Murphy v. Workers' Compensation Appeal Board (City of Philadelphia), 871 A.2d 312 (Pa. Cmwlth. 2005), the employer filed a review petition seeking subrogation for medical payments made to providers.
At the Workers' Compensation Judge's (WCJ) hearing, the claimant alleged that some bills had been paid twice by the employer.
The subrogation specialist testified on cross-examination that she could not be sure if duplicate payments were made and offered to look into the matter.
This court noted that it appeared as if the parties never followed up on the issue and, in fact the WCJ did not address the issue in his adjudication.
The court stated that by merely raising the possibility of duplicate payments, the claimant did not meet her burden of proving that they were paid twice.