PA Commonwealth Court: Massage Therapy by LPN is Reimbursable
The employer in Moran v. WCAB (McCarthy Flowers and Donegal Mutual Insurance) argued that massage therapy did not fall under the duties of a licensed practical nurse.
The Court rejected this argument. The massage therapy was prescribed by a physician and the practical nurse had received instruction in massage therapy as part of her training as an LPN.
Significantly, the Court also noted that the employer had not provided any evidence that massage therapy did not come under the duties of an LPN.