Court of Appeals Affirms Denial of Benefits, Holds Claimant Harmless for Certain Medical Expenses
The court in Ramirez-Trujillo v. Quality Egg, No. 14-0640 (Iowa App. Feb. 11, 2015) addressed issues of causation and medical expenses, and affirmed the decision of the commissioner on both grounds. At the appeal level before the agency, the commissioner held that claimant's condition subsequent to September 30, 2009 was not the result of her work injury on August 1, 2009, and that the employer was responsible for reimbursing claimant for out of pocket medical expenses incurred after September 30, 2009, "because the employer failed to notify Ramirez-Trujillo that the care was no longer authorized as required by Iowa Code section 85.27(4)."
The district court reversed the commissioner's order with respect to medical expenses and affirmed the decision of the district court on the medical causation question. The court found that it was reasonable for the employer to deny payment for the medical costs as claimant told the employer that the treatment was for a separate, non work related injury.
The Court of Appeals first noted that their review of final agency action was "severely circumscribed" and that "the cardinal rule of administrative law is that judgment calls are within the province of the administrative tribunal, not the courts." With respect to the causation issue, the court affirmed the decision of the commissioner on substantial evidence grounds, based on the decision of the district court.
On the medical expense issue, the court noted that section 85.27(4) provides that if the employer chooses the care, the employer shall hold the employee harmless for the cost of care until the employer notifies the employee that care is no longer authorized. The court concluded that the commissioner had no special legislative authority to interpret section 85.27(4), and therefore the question was whether an error at law had been committed. The court, found the statutory language "clear enough" and rejected the employer's argument to "incorporate limiting language in the statute that is not there." The court also found that legal effect was to be given to what the legislature actually said as opposed to they might have said. The court noted that although this imposed a burden on the employer to communicate with employees, this burden was minimal and was implicit, if not required, by the statute. This was also consistent with the liberal construction of the act. The court therefore reversed the decision of the district court on the medical expense issue.
The Ramirez-Trujillo case is potentially important in any situation in which an employer begins care and then ceases to provide that care. The statute, as interpreted by the court, imposes a duty on employers to notify the employee that authorization for care has ended, and unless that notification is provided, the employer continues to be responsible for the care.
The district court reversed the commissioner's order with respect to medical expenses and affirmed the decision of the district court on the medical causation question. The court found that it was reasonable for the employer to deny payment for the medical costs as claimant told the employer that the treatment was for a separate, non work related injury.
The Court of Appeals first noted that their review of final agency action was "severely circumscribed" and that "the cardinal rule of administrative law is that judgment calls are within the province of the administrative tribunal, not the courts." With respect to the causation issue, the court affirmed the decision of the commissioner on substantial evidence grounds, based on the decision of the district court.
On the medical expense issue, the court noted that section 85.27(4) provides that if the employer chooses the care, the employer shall hold the employee harmless for the cost of care until the employer notifies the employee that care is no longer authorized. The court concluded that the commissioner had no special legislative authority to interpret section 85.27(4), and therefore the question was whether an error at law had been committed. The court, found the statutory language "clear enough" and rejected the employer's argument to "incorporate limiting language in the statute that is not there." The court also found that legal effect was to be given to what the legislature actually said as opposed to they might have said. The court noted that although this imposed a burden on the employer to communicate with employees, this burden was minimal and was implicit, if not required, by the statute. This was also consistent with the liberal construction of the act. The court therefore reversed the decision of the district court on the medical expense issue.
The Ramirez-Trujillo case is potentially important in any situation in which an employer begins care and then ceases to provide that care. The statute, as interpreted by the court, imposes a duty on employers to notify the employee that authorization for care has ended, and unless that notification is provided, the employer continues to be responsible for the care.
Comments
Post a Comment