Case Law Update

July 14, 2011

Securitas Security Services v. WCAB (Schuh) 16 A.3d 1221 (Pa. Cmwlth. 2011)


The employer did not file a timely appeal to a UR Determination which found psychotherapy and certain medications for a mood disorder to be reasonable and necessary. The failure to do so did not effectively amend the NCP to include the diagnoses of major depressive mood disorder where the NCP only recognized a low back strain. The basis of this holding is that voluntary payment of medical expenses is not an admission of liability. Furthermore, there is nothing by way of case law or regulation that confers liability on an employer for a specific injury by merely filing a UR request. The Court also noted that the regulations allow an employer to request a UR in medical-only cases even when there has not been an acknowledgment or determination of liability for a work injury, with the condition that the insurer must be liable to pay for treatment found to be reasonable or necessary by an uncontested UR determination.

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