North Carolina Work Injury: The Court in Schatz v. Interfaith Warns of the Effects of Moving Out of State

In our transient society it is commonplace for people to relocate out of state. But how does relocating out of state affect workers’ compensation benefits?
If you have suffered from a work-related injury in North Carolina, it is important to know your rights. Our experienced North Carolina workers’ compensation attorneys can consult with you about your case and guide you through the complex realm of workers’ compensation law.

Schatz v. Interfaith Care Center is a recent workers’ compensation (WC) case out of Minnesota. This case dealt with the law surrounding the receipt of treatment for a work-related injury. Schatz (plaintiff) was employed as a realtor for Interfaith Care Center (Interfaith) located in Minnesota. While working in Minnesota, the plaintiff injured her shoulder. After sustaining the injury the plaintiff moved to Wyoming and she received medical treatment there. The Wyoming medical provider submitted the charges for two shoulder surgeries and treatment to the Interfaith WC insurer, New Hampshire Insurance Company (insurance company). The insurance company compensated the medical provider for the amount consistent with the Wyoming statutes. Because of this, an unpaid balance remained on plaintiff’s account with the medical provider.

Plaintiff filed a WC medical request for payment for the remaining unpaid balance. Plaintiff argued that because the work related injury was sustained in Minnesota, that state law applied to her medical treatment and benefits. And the state law has the general principal of assuring that employees are not held liable for reasonable medical expenses incurred as a result of a work-related injury.

The insurance company argued that because the plaintiff received medical treatment in Wyoming, the Wyoming WC statutes applied. The insurance company relied on Minnesota Statute ยง176.136. This statute indicates that where an employee seeks healthcare out of the state, the employers WC liability to the out of state medical providers is limited to the benefit schedule of the state of the medical treatment. Basically, this Minnesota statute tells the state’s employers that they are only responsible to cover out of state benefits in the amount stipulated in the statute of the state where the employee receives treatment.

After analyzing the relevant state statutes, the court noted some general principals in WC cases. In WC cases as employer is responsible for “furnishing” an injured employee with medical treatment that is reasonably required to cure or relieve that employee of the effects of the work-related injury. Additionally, an employer is responsible for paying any out-of-state medical expenses that are usual and customary charges for the employee’s injuries.

However, the court notes that there is one clear and unambiguous statute that addresses the employers’ liability for paying medical expenses. This statute does not conflict with other state statutes; therefore, it is upheld in this case.

Because there is not statutory conflict, the court found that the Minnesota statute limiting employer’s liability is binding. An employer is limited in liability to out of state medical care provider’s costs to the extent stipulated by the WC statutes of the state where the medical treatment is received. Interfaith won, and was only required to pay the amount stipulated in the Wyoming statute.

This case illustrates the importance of being aware of the contingencies in your WC case.

Contact the Carolina workers’ compensation attorneys at Lee Law Offices, P.A. for legal advice regarding your case and your rights. We are a dedicated law firm that is here to help to protect the rights of injured workers and their families. Call today to schedule a free and confidential appointment. Call 1-800-887-1965.

Additional Resource:

Schatz v. Interfaith Care Center, No. A11-1171 (Minn. S.Ct. Apr. 11, 2012).

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