An employee initiated a civil action against his employer in February 2018, seeking benefits under the Alabama Workers' Compensation Act for a lower-back injury sustained in November 2016. The employee later filed a motion in September 2018, seeking to compel medical treatment, alleging chronic pain from the injury and lack of appropriate care. The employer countered, stating that the employee's authorized treating physician hadn't recommended pain management. Following a hearing, in December 2018, the circuit court ordered the employer to refer the employee to a pain management specialist, based on their assessment of the employee's chronic pain resulting from the work injury. The employer petitioned against this decision.
The central issue was the circuit court's authority to recommend pain-management treatment without any medical opinion supporting its necessity. According to the Act, the employer is obligated to provide "reasonably necessary" medical care. Medical necessity might sometimes be established through lay and circumstantial evidence, but often requires expert testimony, especially for specialized treatments like pain management.
The appellate court agreed with the employer, determining that the circuit court exceeded its discretion by ordering specialized pain-management treatment without sufficient evidence of its necessity. The records did not provide adequate information for a non-medical professional to judge the need for such specialized care. Thus, the appellate court granted the employer's petition and directed the circuit court to rescind its December 6, 2018 order, leaving the door open for the employee to gather more evidence to support his claim in the future.
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