Claimant can sleep better knowing mattress qualifies as medical expense

A realistic and humanitarian interpretation of the Pennsylvania Workers' Compensation Act allows for the provision of a sturdy mattress system, if it is deemed medically reasonable and necessary and causally related to the injury.

Case name: Coker, Bryan v. Duquesne Light Co., 23 PAWCLR 243 (Pa. W.C.A.B. 2008).

Ruling: Under Pennsylvania law, a mattress system not specifically designed for disabled or injured persons may be compensable as a medical expense.

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What it means: A realistic and humanitarian interpretation of the Pennsylvania Workers' Compensation Act allows for the provision of a sturdy mattress system, if it is deemed medically reasonable and necessary and causally related to the injury.

Summary: The claimant filed a review medical petition alleging that the employer refused to pay for reasonable and necessary medical expenses. The claimant wanted the employer to pay for the installation of a Select Comfort air mattress, claiming it would alleviate his discomfort and improve his fatigue. The WCAB rejected the employer's contention that a mattress system was not a compensable expense under the WCA.

The board found that the listing of compensable expenses in the WCA which includes supplies as well as orthopedic appliances, was broad enough to cover a mattress system where medically appropriate. There is no requirement that an item must be specifically designed for disabled or injured persons before it can be compensable.

March 16, 2009

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