Rope and Comcare (Compensation) [2020] AATA 59 (22 January 2020)
Division:GENERAL DIVISION
File Number(s): 2018/2130; 2018/7375
Re:Eleanor Rope
APPLICANT
AndComcare
RESPONDENT
DECISION
Tribunal:Deputy President Gary Humphries AO
Date:22 January 2020
Place:Canberra
The Tribunal affirms the reviewable decision of 20 April 2018.
The Tribunal sets aside the reviewable decision dated 14 December 2018 and instead finds that Mrs Rope is entitled to recover $117.37 pursuant to s 16 of the Safety, Rehabilitation and Compensation Act 1988.
Comcare will pay 20% of Mrs Rope’s costs, as agreed or taxed, pursuant to s 67(8) of the Act.
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Deputy President Gary Humphries AO
Catchwords
COMPENSATION – somatic symptom disorder – two separate claims – whether the applicant is entitled to compensation for psychological medical treatment – reasonableness of psychological treatment considered – decision under review affirmed – whether the applicant is entitled to compensation for medical expenses for Deglycerinated Liquorice – decision under review set aside and substitutedLegislation
Administrative Appeals Tribunal Act 1975
Safety, Rehabilitation and Compensation Act 1988Cases
Alamos and Comcare [2014] AATA 629
Bayani and Australian Postal Corporation [2015] AATA 342
Chowdhary and Comcare [1998] AATA 448
Comcare v Holt [2007] FCA 405
Comcare v Mooi (1996) 69 FCR 439
Durham and Comcare [2014] AATA 753
Popovic and Comcare (2000) 64 ALD 171
Rope and Comcare [2018] AATA 42
Topping and Comcare [2015] AATA 525Secondary Materials
American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders (DSM-5) (5th edition), American Psychiatric Publishing.
REASONS FOR DECISION
Deputy President Gary Humphries AO
22 January 2020
INTRODUCTION
Mrs Eleanor Rope was involved in a motor vehicle accident in March 1987 while employed by ACT Health. Although she returned to work for periods following the accident, she was invalidity retired in 1999.
In June 1987 Comcare accepted liability for shock and injury to Mrs Rope’s neck arising from the accident. Subsequently, it has accepted liability for several conditions which were said related to, or sequelae of, the accident. However, over the more than 30 years following the accident, disputes have arisen between Mrs Rope and Comcare as to her appropriate entitlements under the Safety, Rehabilitation and Compensation Act 1988 (the Act). A number of these have been considered by way of merits review by the Tribunal; some have also been further considered by the Federal Court. It should be noted that Mrs Rope has, on a number of such occasions, successfully asserted in those forums her right to particular forms of compensation under the Act.
The present proceedings concern two specific claims for compensation arising out of her 1987 motor vehicle accident.
Although Mrs Rope has generally appeared on her own behalf before the Tribunal in her various proceedings, in the present matter she was represented by counsel, Mr Anforth and Mr Livingston, instructed by solicitors, for the hearing before the Tribunal in October 2019. However, she wrote to the Tribunal in December 2019, following the lodgement of final submissions by the parties, advising that…
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- Rope and Comcare (Compensation) [2020] AATA 59
- Case
- [2020] AATA 59
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Tribunal were whether the psychological counselling Mrs Rope sought was obtained in relation to her compensable injury, whether such treatment was reasonable in the circumstances, and if so, what amount of compensation was appropriate. For the DGL tablets, the Tribunal had to determine if the medical expenses were recoverable under the relevant legislation.
Regarding the psychological counselling, the Tribunal affirmed the reviewable decision that Mrs Rope was not entitled to compensation. This decision was based on the reasoning that while Mrs Rope suffered from a condition that arose from her 1987 motor vehicle accident, and which was accepted as compensable, the extensive psychological counselling received by February 2018 was no longer considered reasonable treatment for that condition. The Tribunal noted that much of the distress addressed by the counselling was generated by Mrs Rope's interactions with Comcare and her focus on litigation, suggesting that such support could be provided by non-insurer funded sources. In contrast, the Tribunal set aside the reviewable decision concerning the DGL tablets. It found that Mrs Rope was entitled to recover $117.37 for the cost of these tablets and their postage, as this treatment was considered the best option for her reflux oesophagitis, with alternatives causing undesirable side effects. The Tribunal ordered Comcare to pay 20% of Mrs Rope's costs.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
In her live evidence to the Tribunal, Prof Hillman said that she had been treating Mrs Rope since 1997. She considered that the liquorice (the DGL) served to control the sensitisation of the oesophagus to the irritation of the reflux. Gastro-oesophageal reflux can be produced by stress. She said that in Mrs Rope’s case DGL was the best treatment because the alternatives all caused various unfortunate side effects such as increased blood pressure, extreme unpalatability and/or severe constipation. She agreed to that Mrs Rope might now trial antacids to achieve the same effect as DGL, but we did…18 years ago trial a whole pile of things which didn’t work and the liquorice did, which is why we used it.CONSIDERATIONPsychological counselling – Application 2018/2130Comcare’s submissions As explained above, Comcare submitted that it had impliedly accepted liability for a depressive disorder on 13 July 2000 at the time when liability for permanent impairment and non-economic loss for a psychiatric condition was accepted under ss 24 and 27 of the Act. Initially, Comcare contended that the psychiatric condition from which Mrs Rope was suffering in February 2018, at the time of the reviewable decision in issue here, was not the same condition as that accepted in July 2000. However, that contention was not pressed at the hearing. In its closing submissions Comcare said that a psychiatric condition satisfying the test of being outside the boundaries of normal mental functioning and behaviour (Comcare v Mooi (1996) 69 FCR 439 at 444) had been present from 2000 until the reviewable decision in 2018. It accepted that this condition bears the necessary relationship to employment to be compensable, subject to the provisions of s 16. The correct description of that condition (now if not in 2000) is somatic symptom disorder, Comcare submitted. Ms Wright, Counsel for Comcare, submitted that Mrs Rope had received 600-700 psychological counselling sessions to treat both the psychological symptoms arising from her painful neck condition and psychiatric condition accepted in July 2000. Counsel contended that, by February 2018, the sessions were no longer being delivered in relation to any compensable condition or, if they were, they were not reasonable treatment of any such condition. Comcare also submitted that much of the distress which the counselling was addressing was generated by Mrs Rope’s interaction with Comcare, as well as by an unhealthy focus on her condition which, in line with the evidence given by Dr Jetnikoff, was being exacerbated by continuing medical intervention. A cessation of psychological counselling with a consequential reduction in her dealings with Comcare would address both these issues, Comcare maintained. Ms Wright characterised many of the psychological treatment sessions as supportive counselling, i.e. a chance for Mrs Rope to express her frustrations about litigation with Comcare and other life issues, with little else of a therapeutic nature. Counsel contended that such support could be provided by a friend or a minister, and did not need to be insurer-funded. She drew on Dr Jetnikoff’s report as support for this proposition.Mrs Rope’s submissions