The Commonwealth Court of Pennsylvania has ruled in a case of first impression that chiropractors who treat workers' compensation claimants are not entitled to payment for routine office visits in addition to payment for procedures that are performed during those visits.

In Sedgwick Claims Management Services v. Bureau of Workers' Compensation, Fee Review Hearing Office (Piszel and Bucks County Pain Center), a three-judge panel of the court vacated an order of a Bureau of Workers' Compensation fee review hearing officer, which had required plaintiff Sedgwick Claims Management Services to pay chiropractor Michael Piszel for 39 office visit charges of $78 each in addition to charges for treatments provided at those visits.

The charges were incurred in the course of Piszel's treatment of workers' compensation claimant Robert Grivner, according to the Commonwealth Court's opinion. Sedgwick, as Grivner's employer's third-party workers' compensation insurance administrator, paid Piszel for shoulder and neck treatments he provided to Grivner during those visits but denied the claims for the additional office visit charges. Sedgwick argued that nothing was done during those appointments beyond routine examinations and evaluations related to the shoulder and neck treatments.