Superior Court Rules on Scope of Obligation of First Party Carriers to Pay Chiropractors for Treatment Rendered by Staff

In the recent Superior Court decision in the case of State Farm Mut. Auto. Ins. Co. v. Cavoto, 2018 Pa. Super. 285 (Pa. Super. Oct. 17, 2018 Gantman, P.J., Shogan, J., and Blatt, J.) (Op. by Shogan, J.), the court addressed an appeal from a declaratory action filed by State Farm seeking a judicial declaration that it was not obligated to pay the chiropractor for treatments and procedures delegated to, and perform by, chiropractic support personnel without special licenses or certifications.  

The Superior Court held that the chiropractor cannot be expected to be paid by a first party carrier for such services performed by unlicensed support personnel.  

Anyone wishing to review a copy of this decision may click this LINK.

I send thanks to Attorney Scott B. Cooper of the Harrisburg, Pennsylvania law firm of Schmidt Kramer for bringing this case to my attention.