In Patricia Mikulan v. Drug Abuse Foundation of Palm Beach County, Inc. and PMA Management Corporation outstanding medical bills for unauthorized care were the focus of this litigation. Because there was no dispute the requested bills and medication reimbursement originated with unauthorized providers, the JCC reviewed the evidence to determine whether the subject medical constituted emergency or self-help care as defined by law. That review ended with the conclusion that claimant had failed to meet her burden of proof. Medical care from unauthorized providers DENIED. Regarding a claim for physical therapy, the E/C defended the recommending doctor had exceeded the scope of his authorization for a second opinion. The JCC accepted the evidence establishing claimant had not received sufficient therapy following her surgery and therapy was GRANTED.
