EMPLOYMENT LAW
Adam Beyer
In Alaska State Commission for Human Rights v. United Physical Therapy, 484 P.3d 599 (Alaska 2021), the supreme court held that the Alaska Workers’ Compensation Board acted reasonably when it interpreted the merits of a provider’s claim to require a review of the underlying medical care. (Id. at 606–07). The case arose after a medical provider claimed that a state agency should pay the medical bills of a state employee injured in a workplace accident. (Id. at 601). Initially unrepresented by counsel, the medical provider’s claims before the Board were somewhat ambiguous about whether they were challenging the state’s ability to controvert the claim or the claim’s underlying medical justification. (Id. at 602–04). Under Alaska law, the Board would not have jurisdiction to hear a challenge to controversion but would be able to award compensation for a contested payment after hearing evidence. (See id. at 606–07). The Board interpreted the medical provider’s claim as the latter, so it reviewed medical evidence presented and found the costs reasonable, ordering the state to pay. (Id. at 603–04). On appeal from the Alaska Worker’s Compensation Appeals Commission’s affirmance of the Board, the state argued that the Board impermissibly altered the merits of the provider’s claim. (Id. at 606). The supreme court rejected this argument, emphasizing the governing statute’s summary nature and the Board’s duty to assist unrepresented litigants. (Id. at 607). Affirming the Alaska Workers’ Compensation Appeals Commission’s decision, the supreme held that the Alaska Workers’ Compensation Board acted reasonably when it interpreted the merits of a provider’s claim to require a review of the underlying medical care. (Id. at 606–07).
