There are those injured workers who seek to maintain activities of daily living through "passive modalities" such as massage therapy, ostensibly saving the insurance company the cost of much more expensive treatment.

More numerous are those insurance carriers who do not consider massage therapy to be "medical treatment" at all, and seek to avoid paying for such care — ironically at any costs. "Wouldn't we all love to stay home from work and get a massage," the cynical criticism goes.

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