Melo v. Barnett

I respectfully dissent.

The Appellant, Dr. Melo, argues he was required by KRS 342.020 to provide his treatment notes, along with his statement for services, regarding his treatment of Steven Barnett, notwithstanding the provisions of KRS 214.181. I do not agree.

Under the workers’ compensation scheme for payments of medical services, KRS 342.020(1), the employer or others acting on his behalf are required to make payments for services rendered to an employee within 30 days of receipt of a “statement for services.” 803 KAR 25:096, Section 1(5) defines a “statement for services” as a completed…