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Out of State Medical Treatment in Boston Workers’ Compensation Discussed by the Court in Schatz v. Interfaith

Workers’ compensation was created in order to provide benefits to employees who have been injured on the job. However, Boston workers’ compensation has limitations as well.
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Our experienced Boston injury attorneys can help inform you of your rights in your workers’ compensation case. Understanding your rights can help you get the benefits and medical care you are entitled to.

A recent case was heard in Minnesota that discusses the law that governs the employer liability for medical treatment an injured employee receives. Schatz v. Interfaith Care Center, No. A11-1171 (Minn. S.Ct. Apr. 11, 2012). Schatz (plaintiff) worked as a realtor for Interfaith Care Center (Interfaith) and was a resident of Minnesota. While working in Minnesota, the plaintiff severely injured her shoulder. Although she received medical treatment in Minnesota, she decided to relocate out of state to Wyoming. She sought treatment for her shoulder from a medical provider in Wyoming. This medical care provider conducted two surgeries on the plaintiff’s shoulder, which were a direct result of the work-related injuries plaintiff sustained. This Wyoming medical provider submitted the bills for shoulder surgery and treatment to the Interfaith WC insurer, New Hampshire Insurance Company (insurance company).

Upon receipt of the coverage requests, the insurance company sent the medical provider the amount consistent with the Wyoming WC statutes. The amount sent to the provider did not equal the cost of the treatment which left the plaintiff owing the provider money. Plaintiff entered a WC “medical request for payment” with the insurance company to have the remaining balance covered. The insurance company denied her request; thus, leading to the case at hand.

Plaintiff argued that because the state statute says that an injured employee should not be held liable for medical costs associated with a work-related injury, she should not have to pay the outstanding balance. Additionally, plaintiff supported her argument with the contention that because she was injured in Minnesota, this Minnesota law had to be upheld.

The insurance company argued that Minnesota law does apply but it pointed to a different Minnesota law. The insurance company defended itself by arguing that it was not responsible for the additional payments because of the Minnesota statute discussing the employer’s liability for medical treatment costs. This statute says that where an employee is injured in one state and receives medical treatment in another, the employer’s liability for medical treatment costs is limited to the amount stipulated by the state where the medical treatment is obtained. See Minnesota Statute §176.136.

Plaintiff countered this argument by stating that there was a conflict between the Minnesota state WC statutes that rendered the result unconstitutional.

The court looks to the facts of this case and analyses the statute. The statutes in question were both unambiguous and clear as to their intent and meaning. Where an employee suffers a work related injury, the employer is legally responsible for “furnishing” an injured employee with the reasonable costs associated with the employee’s medical care. Additionally, there is the above referenced Minnesota statute that limits the amount the employer has to pay for out of state treatment by imposing the statute of the state of treatment. However, the court found that the statutes did not conflict as they addressed two different issues.

The court found for Interfaith, and the plaintiff was denied the additional coverage she requested.

If you have been involved in a work related accident, contact the injury attorneys at Law Offices of Jeffrey S. Glassman to schedule your free consultation. Call 888-367-2900.