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Davis Brown Employment and Labor Law Blog

Sorry, Honey! What's Mine is Not Yours. - February 19, 2015

In Iowa, an employer directs medical care in an accepted workplace injury and may lawfully deny treatment unrelated to the injury. In a recent case, Hoyt v. Wendling Quarries and United Heartland, treatment was found unrelated to the injured worker.


An injured worker’s spouse/caregiver sought counseling to help her adjust to her husband’s traumatic workplace injury that resulted in a left shoulder amputation and severe mental health conditions, including PTSD and dementia. The authorized mental health provider for the injured worker found the spouse would benefit from counseling because of her role as a caregiver. The work comp carrier refused to pay for the treatment.


The injured worker sought relief from the Worker’s Compensation Division, who agreed with the comp carrier. The case was appealed and ultimately heard by the Court of Appeals who affirmed the work comp carrier’s refusal to approve treatment.

The Court noted there is Iowa case law requiring a work comp carrier to authorize family counseling, when the injured worker also participates. Relying on this distinction, the Court found the treatment, while a secondary benefit to the injured worker, was really medical treatment for the spouse.


The lesson learned from this case: a work comp carrier may deny treatment of an injured worker’s family members, and require that covered healthcare treatment is only for the primary benefit, not secondary, of the injured worker.

Employers in this situation might consider whether the Employee Assistance Program or “EAP” would apply to the spouse and provide counseling.