Ellis v. McCall Insulation

In this workers’ compensation proceeding, the primary issue is whether an insurer must pay chiropractic bills unrelated to a compensable injury absent the issuance of a formal denial. In the circumstances of this case, we conclude that payment is not required.

In 1979, claimant injured his back. He filed a workers’ compensation claim, which the insurer accepted. Ultimately, an award of 10 percent unscheduled permanent partial disability was rendered.

Immediately upon injury, claimant began chiropractic treatments. The insurer paid for all the treatments until December 1984. The insurer then…