Court of Appeals Concludes that Counseling for Spouse of Injured Worker is not Mandated by Section 85.27
Hoyt v. Wendling Quarries , No. 14-0800 (Iowa App. Feb. 11, 2015), presented the interesting question of whether section 85.27 of the Code required or allowed for payment for counseling for the spouse of the injured worker, when that counseling was recommended by an authorized treater for the claimant. Ultimately, the Court of Appeals concluded, as had the agency, that section 85.27, did not require payment for such treatment by the employer. Claimant suffered severe physical injuries while working, and subsequently developed depressive disorder, post-traumatic stress disorder and dementia. He was ultimately found permanently and totally disabled, and that decision was not a part of the case before the Court of Appeals. During claimant's treatment for his injury, Dr. Michael March, the authorized mental health provider, recommended that claimant and his wife engage in individualized counseling. Claimant's wife was his primary caretaker and Dr. March stated that she w...