Workers Comp Reimbursement for Care Provided by Disabled Employee's Wife

In Petrilla v. Workmen's Compensation Appeal Board (People's Natural Gas), 692 A.2d 623 (Pa. Cmwlth. 1997), the claimant's work injury rendered him a paraplegic requiring home nursing care. The claimant's wife received training for home nursing care, and the claimant subsequently sought reimbursement for the care provided by his wife. In denying the claim for benefits, this Court held that the claimant's wife provided the type of care that family members normally provide for an injured loved one and were not reimbursable. The Court reasoned as follows: Services provided to a claimant by someone who is not a licensed practitioner of the healing arts, to be recoverable under Section 306(f)(1), must be provided under the supervision of a practitioner, or at a minimum, by a referral from the practitioner. Section 306(f)(1) was renumbered as Section 306(f.1)(1) by Act 44.