e-Journal Summary

e-Journal Number : 73866
Opinion Date : 09/17/2020
e-Journal Date : 09/21/2020
Court : Michigan Court of Appeals
Case Name : Belcher v. Ford Motor Co.
Practice Area(s) : Workers' Compensation
Judge(s) : Tukel, Cavanagh, and Borrello
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Issues:

Whether plaintiff’s massage therapy was compensable as worker’s compensation under MCL 418.351(1); Reimbursement under the Worker’s Disability Compensation Act (MCL 418.101 et seq.); “Physical therapy services”; MCL 418.315(1); DiBenedetto v. West Shore Hosp.; Public Health Code (MCL 333.1101 et seq.); “Practice of physical therapy”; MCL 333.17801(d); MCL 333.17819; Michigan Compensation Appellate Commission (MCAC)

Summary

Holding that plaintiff-employee’s massage therapy was not compensable as worker’s compensation under MCL 418.351(1), the court vacated the MCAC’s order requiring defendant to pay for plaintiff’s massage therapy and remanded. The court held “that massage therapy is a form of physical therapy, which was not ordered by a doctor; consequently, plaintiff did not receive his massage therapy ‘pursuant to a prescription from a health care professional.’” The court also held “that because massage therapy is physical therapy, and because the massage therapist who treated plaintiff was neither a licensed physical therapist nor a physical therapist assistant under the supervision of a licensed physical therapist, the massage services were not compensable in any event.”

Full PDF Opinion