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Tennessee caps workers' comp bills after denied treatment dispute
The Workers' Compensation Appeals Board certified its decision on August 7, 2026, upholding Tennessee's medical fee schedule cap even when care was performed without authorization.
Tennessee's Workers' Compensation Appeals Board has certified a final ruling that limits an employer's liability to the state's medical fee schedule for workers' compensation treatment, even when the employer initially denied care and was later found responsible. The board finalized the decision on August 7, 2026, ending a dispute over how much an employer must pay for treatment it previously refused.
The case began with a Fresenius Medical Care Holdings, Inc. worker who fell through rotted wood while delivering on November 12, 2018, injuring his low back and right knee. The employer accepted the knee injury but contested the back claim, attributing it to a pre-existing condition.
After a spine surgeon recommended fusion, the employer sought a second opinion, which concluded the need for surgery was not primarily caused by the work injury. The employer denied the surgery, and the worker proceeded anyway with surgery, physical therapy, and pain management that were all unauthorized.
At trial, a court found the back condition represented a permanent worsening of a pre-existing injury and awarded permanent partial disability and future medical benefits, ordering the employer to pay unauthorized bills but capped at Tennessee's medical fee schedule. The worker argued the bills were $562,783.85, while the employer said $147,979.91, but the board said Tennessee law limits liability to maximum allowable fees and treats authorized and unauthorized bills the same, adding that providers generally cannot pursue claimants for balances and noting the workers' out-of-pocket concern was speculative.