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Injured worker's caretaker wife not eligible for mental health therapy


An Iowa employer should not pay for therapy for an injured worker’s wife who has been the primary caretaker for her husband since his work accident, an Iowa appeals court has ruled.

Craig Hoyt worked for DeWitt, Iowa-based Wendling Quarries Inc. and suffered a traumatic work-related injury, court records show. His injuries included multiple rib fractures, right ankle and right knee fractures, a right cerebellar infarction and trauma to his left shoulder and arm.

The accident left Mr. Hoyt with severe mental health conditions, including post-traumatic stress disorder and dementia, and his left shoulder and arm were amputated in the aftermath of the accident, records show. As such, Wendling Quarries which was insured for workers comp by Milwaukee-based United Heartland Inc., authorized Mr. Hoyt to receive mental health treatment with Dr. Michael March in Cedar Rapids, Iowa, as part of his workers comp claim.

Dr. March recommended that Mr. Hoyt and his wife, Amy, participate in individualized counseling in March 2013, according to court filings. Ms. Hoyt was Mr. Hoyt’s primary caretaker, and the doctor opined in a letter to Mr. Hoyt’s attorney that Ms. Hoyt would “be better able to provide what he needs if she can manage her own distress and adjustment more effectively.”

Wendling Quarries denied payment for Ms. Hoyt’s counseling, and Mr. Hoyt’s attorney filed a petition seeking to compel Wendling to pay for her treatment, according to filings. The Iowa Workers’ Compensation Commission denied the petition, finding that Wendling was only liable to pay for treatment related to its injured employee and not other people.

The Polk County, Iowa District Court affirmed the commission’s decision, and Mr. Hoyt appealed to the Iowa Court of Appeals.

A three-judge panel of the appellate court unanimously affirmed the lower court rulings on Wednesday, finding that Iowa workers comp law “does not require the employer to pay for individualized counseling services for someone other than the injured employee even where such treatment may benefit the injured employee.”

While Mr. Hoyt’s mental health provider “opined that Craig’s spouse may benefit from individualized counseling services, which may indirectly benefit Craig, such services are directed to the spouse’s mental health condition and not ‘the injury,’ which is Craig’s compensable injury suffered in the course of his employment with the employer,” the ruling reads.

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