Yeats and Comcare [2017] AATA 80 (27 January 2017)
Oliver and Comcare [2017] AATA 252 (28 February
2017)
Key Points
- In both cases, the Tribunal was required to consider whether
physiotherapy treatment constituted reasonable medical treatment
pursuant to section 16 of the SRC Act.
- The lesson to be learnt from the cases is that whether
physiotherapy should be considered to be reasonable medical
treatment depends on the facts and circumstances of each case.
Background
In Yeats, Ms Yeats applied to the Tribunal for review
of a decision concerning her entitlement to compensation for
medical treatments, being prolotherapy (an alternative therapy
which involves the injection of an irritant into affected areas)
and physiotherapy, in connection with injuries suffered during her
employment. Ms Yeats stated that she found physiotherapy treatment
to be particularly beneficial to improve function and movement of
the upper limbs, shoulders and neck. The evidence
