Housekeeping Expenses Considered Recoverable Medical Expense by WCAB (Reese v. All Saints Health Care)

The WCAB reversed a WCJ opinion that housekeeping services could not be considered “medical treatment necessary to cure or relieve” in Reese v. All Saints Health Care, 2015 Cal. Wrk. Comp. P.D. LEXIS 570 [2015 Cal. Wrk. Comp. P.D. LEXIS 570].    The court indicated that a myriad of home health care services could be considered medical treatment.  Despite this finding the court did not indicate that this particular use of home health care was necessarily appropriate and returned the matter to the trial level for that determination.

In the bigger picture, what has yet to be determined is how home health care such as housekeeping services would be handled within the context of utilization review, IMR and the strictures of medical treatment guidelines.  This would seem to be the more important issue as utilization review and IMR should be a strong gatekeeper as it concerns home health care.

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