TWCA Reviews Whether a Hydrotherapy Tub Falls Within the "Future Medical Treatment" Provision of a Workers' Compensation Settlement

JERRY LINDSEY v. TIM REEVES D/B/A TIM'S TREE SERVICE (TWCA June 16, 2011)



The employee suffered a compensable spinal cord injury. He settled his workers' compensation claim with his employer in 2007. The settlement provided for future medical treatment in accordance with Tennessee Code Annotated section 50-6-204(a) (2008). In 2009, the employee sought authorization and payment for a hydrotherapy tub. His employer declined to authorize installation of the tub. The employee filed a motion for authorization of medical care in February 2010 and supported the motion by attaching a note from his authorized treating physician that he would "benefit" from use of the tub. The trial court granted the motion. On appeal, we reverse.


Opinion available at:

http://www.tba2.org/tba_files/TSC_WCP/2011/lindseyj_061611.pdf