Is Psychotherapy Provided by a Licensed Registered Nurse Com ?
In Morwald v. Workmen's Compensation Appeal Board (Eng'g & Refrigeration, Inc.), 143 Pa. Commw. 511, 599 A.2d 307 (Pa. Cmwlth. 1991) the Court considered whether psychotherapy provided to the claimant by a licensed registered nurse, board-certified in psychiatric nursing, was compensable under Section 306(f)(1), then in effect.
Agreeing with the claimant that it was error for the Board to require that the nurse be a licensed psychotherapist when none exists, the Court nonetheless affirmed the Board's decision on alternate grounds.
The Court announced its holding "that psychotherapy, as a modality of treatment, is a medical service, not a separate field of the healing arts which requires specific licensure as a prerequisite to coverage under 306(f)." Id., 599 A.2d at 309.
Its reasoning is stated in part as follows at 309:
Psychotherapy ... is a therapeutic or corrective measure, which O'Connor the registered nurse is not licensed to prescribe.
O'Connor may have been qualified by virtue of her nursing license to provide psychotherapy according to a regimen prescribed by a healing arts practitioner whose license includes diagnostic and prescriptive functions.
Still, without supervision by, or at a minimum, a referral from such a practitioner, the psychotherapy rendered by O'Connor does not come within the provisions of 306(f).