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Worker establishes need for dental implants following assault


An appeals court in Arkansas upheld a finding that a worker’s injury was causally linked to her tooth decay and her subsequent need for dental implants.

However, the court ruled she was not entitled to recover the cost of the surgery to extract her upper teeth, because she had not sought preauthorization.

Tara Rowland was working for the Evangelical Lutheran Good Samaritan Society at a senior living facility when a patient struck her in the face in 2014, chipping one of her teeth, according to Evangelical Lutheran Good Samaritan Society v. Rowland.

A medical scan showed conditions that required surgery, which was unsuccessful. Two doctors then recommended orthodontic braces and more surgery after the braces were removed. Evangelical Lutheran argued there was no causal connection between the compensable injury and the recommended treatment.

An administrative law judge disagreed. Following more treatment, she developed dental caries and her upper maxilla became infected.

One doctor determined that it was necessary to extract all of Ms. Rowland's upper teeth and did so without seeking preauthorization. That doctor recommended dental implants.

The doctor also opined that Ms. Rowland's remaining lower teeth would also require extraction and dental implants, and he attributed her condition to the delays in treatment caused by Evangelical Lutheran’s denying the claim.

The ALJ also found that Ms. Rowland's dental caries was causally linked to her original injury, and the implants were reasonably necessary. However, the judge found Ms. Rowland was not entitled to recover the cost of the extraction because she failed to obtain preauthorization. The Workers’ Compensation Commission affirmed.

The Arkansas Court of Appeals said there was substantial evidence to support the finding that Ms. Rowland was entitled to additional treatment, as her doctor described dental and jaw problems that were the direct result of delays in treatment due to Evangelical Lutheran’s denying the claim.

However, the court said the commission properly relied on the doctor’s testimony that Ms. Rowland's condition was not a “life or death” situation and concluded she was not entitled to have the cost of the extraction covered.

WorkCompCentral is a sister publication of Business Insurance. More stories here.