Workers’ Compensation Refusal to Pay Does Not Relieve a No-Fault Insurer of Its Obligation

When a workers’ compensation insurer refuses to pay for chiropractic services because it was determined that services are excessive according to the standards established by the workers’ compensation rules, this does not relieve an automobile insurer of its obligation to pay basic economic loss benefits and to reimburse its insured for the expense of chiropractic services. While driving a school bus for her employer, Rodriguez was injured when a vehicle crashed into her bus. The workers’ compensation insurer paid for 12 weeks of chiropractic treatment under the treatment parameters; however, they would not pay for additional treatment. She then continued receiving chiropractic treatment, which she submitted to her automobile insurer, State Farm. State Farm failed to pay for this treatment. The court noted the legislature’s intended purposes of both the No-Fault Act and the Workers’ Compensation Act are for the insured to receive prompt payment of medical benefits to which he or she is entitled. State Farm will have to pay the overdue benefits, but will be entitled to reimbursement if it is ultimately determined that they are covered under the Workers’ Compensation Act.

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