Aylett and Comcare (Compensation) [2019] AATA 1474 (26 June 2019)
Division:GENERAL DIVISION
File Number(s): 2016/4269
Re:Melissa Aylett
APPLICANT
AndComcare
RESPONDENT
DECISION
Tribunal:A G Melick AO SC, Deputy President
Date:26 June 2019
Place:Hobart
The decision under review is affirmed.
................................[sgd].....................................
A G Melick AO SC, Deputy President
COMPENSATION – liability for medical expenses – determinations ceasing liability for medical expenses – whether material contribution to Applicant’s condition by employment – reasonableness of treatment – massage treatment – physiotherapy treatment – decision under review affirmed
Legislation
Safety, Rehabilitation and Compensation Act 1988 (Cth), s 16
Cases
Dunstan v Comcare [2011] FCAFC 108; (2011) 125 ALD 362
Rope and Comcare [2018] AATA 42; 158 ALD 183
Secondary Materials
The Clinical Framework for the Delivery of Health Services, WorkSafe Victoria
REASONS FOR DECISION
A G Melick AO SC, Deputy President
26 June 2019
The Applicant, Ms Aylett, was employed by the Australian Taxation Office (ATO) from May 1990 until 2001. She performed various administrative roles at the ATO, including a period of data entry associated with cheque processing.
In December 1998 the Applicant signed a claim for compensation in respect of a right shoulder injury, which she said she first noticed in November 1998.[1] She described the injury as ‘right arm/neck/shoulder aggravated again’ and noted that it was the same injury as one suffered in August 1993. The Applicant did not have any time off work.
[1] T5, p 9.
It appears the Applicant had previously had an injury in October 1993. Clinical notes from that time refer to right carpal tunnel, right de Quervains and pain in the left and right trapezius.[2] A clinical note from November 1995 describes a right shoulder and neck/right arm injury from 25 August 1993 that flared up each year.[3]
[2] Exhibit 3.
[3] Exhibit 3.
The 1998 compensation claim was accepted by the Respondent and it is common ground that since that time the Applicant has continued to obtain treatment in the form of massage and physiotherapy. Her ongoing symptoms are chronic neck pain, right sided shoulder and arm pain, right neck and shoulder spasms and migraines.
In June 2015 the Respondent issued a determination ceasing liability for physiotherapy treatment under s 16 of the Safety, Rehabilitation and Compensation Act 1988 (SRC Act) for the condition of ‘disorders of muscle, ligament, & fascia (right)’.[4] The determination set out a physiotherapy treatment plan that, from 25 June 2015, decreased in frequency until ceasing treatments totally by 30 November 2015. Between 19 November 1998 and 30 March 2016 the Applicant received treatment on some 679 occasions.
[4] T37.
In April 2016 the Respondent issued a separate determination that it was no longer liable to pay for massage treatment under s 16 of the SRC Act for the same condition of ‘disorders of muscle, ligament, & fascia (right)’.[5]
[5] T42.
The Applicant sought review of the decisions referred to at paragraphs 5 and 6 above and on 17 June 2016 the…
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- [2019] AATA 1474
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CaseChat Overview and Summary
The AAT was required to determine whether the Applicant's employment at the ATO materially contributed to her current ailments, and if so, whether the physiotherapy and massage treatments she sought were reasonable treatment for those ailments. The Applicant's case relied on her assertion that she was asymptomatic before commencing her ATO role and that her symptoms directly correlated with her work duties. However, during cross-examination, it emerged that the Applicant had been involved in several motor vehicle accidents in the past, which had resulted in injuries and symptoms such as whiplash, neck pain, and shoulder pain.
The Deputy President accepted that the Applicant was honest in her evidence but found that her recollection of significant past traumas, specifically the motor vehicle accidents, had undermined the effect of much of her testimony. Despite this, the Deputy President found that if there was a material contribution to the Applicant's ailment from her employment at the ATO, then massage administered by a physiotherapist and physiotherapy treatment would be considered reasonable treatment. Ultimately, the AAT affirmed the decision to cease payment for the treatments.
Orders
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Background
Background to the litigation
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Evidence
Evidence Before The Court
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Reasons for decision
Ratio Decidendi
Legal Principle Established
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