Sincock and Comcare (Compensation) [2018] AATA 1635 (12 June 2018)
Division:GENERAL DIVISION
File Number(s): 2016/4660; 2016/4661
Re:Patricia Sincock
APPLICANT
AndComcare
RESPONDENT
DECISION
Tribunal:Senior Member D. J. Morris
Date:12 June 2018
Place:Melbourne
The reviewable decision of 1 April 2016 that the Applicant is not entitled to compensation for physiotherapy treatment and is entitled to compensation for general practitioner consultations and fortnightly myotherapy sessions from 11 February 2016 to 2 March 2016, pursuant to section 16 of the Safety, Rehabilitation and Compensation Act 1988 (the SRC Act), in relation to her accepted injury is affirmed.
The reviewable decision of 26 May 2016 that the Applicant is not entitled to compensation for myotherapy treatment, pursuant to section 16 of the SRC Act, is affirmed.
...........................[sgd].............................................
Senior Member D. J. Morris
Catchwords
COMPENSATION – medical treatment – ongoing physiotherapy and myotherapy – evidence of degenerative condition – whether treatment is in relation to the accepted injury – decision affirmed
Legislation
Safety, Rehabilitation and Compensation Act 1988, ss 14, 16
Cases
Re Popovic and Comcare [2000] AATA 264
REASONS FOR DECISION
Senior Member D. J. Morris
XX June 2018
Mrs Patricia Sincock is the Applicant in this matter. She seeks review of a decision made by the Respondent on 1 April 2016 which affirmed two earlier determinations dated
10 February 2016 and 11 February 2016 that the Applicant is not entitled to compensation for physiotherapy treatment and that she is entitled to compensation for general practitioner consultations and fortnightly myotherapy sessions from the period
11 February 2016 to 2 March 2016, under section 16 of the Safety, Rehabilitation and Compensation Act 1988 (the SRC Act) in relation to Mrs Sincock’s accepted injury of ‘whiplash injury to neck and upper back and strain to right knee.’ This is application 2016/4660.
Mrs Sincock also seeks review of the Respondent’s decision of 26 May 2016 which affirmed an earlier determination dated 24 March 2016 that the Applicant was not entitled to compensation for myotherapy treatment under section 16 of the SRC Act in relation to the accepted injury. This is application 2016/4661.
The hearing was held on 26 and 27 February 2018. Mrs Sincock represented herself, made submissions, gave evidence and was cross-examined by Ms Julia Lucas of counsel, for the Respondent. On 27 February 2017 Mr Iain Kelman, FRACS, consultant orthopaedic surgeon, gave evidence.
The Tribunal admitted into evidence documents submitted by the Respondent under section 37 of the Administrative Appeals Tribunal Act 1975 (T-documents).
The Tribunal also admitted the following documents into evidence:
(a)Medical letter from Dr P. Ramachandran, neurology registrar at St Vincent’s Hospital, Melbourne, dated 6 June 2017.
(b)‘To whom it may concern letter’ from Dr P. Ramachandran, also dated 6 June 2017.
(c)Medical letter from Dr Craig McColl and Professor Malcolm Horne of Monash Neurology, dated 9 August 2000.
(d)Medical letter from Professor Malcolm Horne, dated 24 October 2000.
(e)MRI Cervical Spine performed on 14 February 2017.
(f)Medical report by Mr Ben Kewish, physiotherapist, dated 27…
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- AGLC
- Sincock and Comcare (Compensation) [2018] AATA 1635
- Case
- [2018] AATA 1635
- Decision Date
CaseChat Overview and Summary
The primary legal issues before the Tribunal were whether the physiotherapy and myotherapy treatments sought by Mrs Sincock were in relation to her accepted injury, and whether such treatments were reasonable in the circumstances, as required by section 16 of the *Safety, Rehabilitation and Compensation Act 1988* (Cth). The Tribunal was required to consider the evidence regarding the nature of Mrs Sincock's current symptoms, the cause of those symptoms, and the efficacy of the proposed treatments in addressing the accepted injury.
The Tribunal considered evidence from various medical professionals, including reports from Dr King, Mr Kelman, Dr O’Donnell, Dr Sillcock, Mr Xenos, and Mr Kewish. It was noted that while initial recommendations for myotherapy were considered reasonable following the accident, Mrs Sincock herself had ceased this treatment, believing it was not substantially different from physiotherapy and no longer of benefit. The Tribunal found the reasoning in *Re Popovic and Comcare* persuasive, concluding that passive physiotherapy treatment that offered limited or no long-term benefit, and potentially no short-term benefit, was not reasonable. Similarly, the Tribunal accepted Mrs Sincock's concession that myotherapy was no longer of benefit. Regarding physiotherapy, the Tribunal noted that medical opinions, including that of Mr Kelman, suggested that the applicant's spinal problems were primarily caused by ageing and degenerative changes, rather than the 1996 motor vehicle accident. While Mr Kewish's physiotherapy regimen was considered reasonable for a person with degenerative cervical spine issues, it was viewed as treating spondylosis, not the injury sustained 20 years prior.
The Tribunal affirmed the reviewable decision, finding that the myotherapy treatment was no longer reasonable treatment within the bounds of section 16 of the *SRC Act*, as there was no evidence of continuing beneficial effects. The Tribunal also found a lack of clarity regarding the ongoing necessity of physiotherapy in relation to the accepted injury, given the evidence pointing towards degenerative changes as the primary cause of current symptoms.
Orders
Orders of the court
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Background
Background to the litigation
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Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
In terms of impacts on Mrs Sincock’s functional abilities, the Respondent noted that she works full-time, and indeed is now CEO of her jointly owned company, and plays sport regularly. Therefore, the Respondent submitted the Applicant has a significant level of functionality.Consideration The Tribunal will first consider the delegate’s decision of 26 May 2016 which affirmed a determination of 24 March 2016 that the Applicant has no continuing entitlement for myotherapy treatment in relation to her accepted injury. Mr Kelman in his evidence agreed that the original recommendation to Mrs Sincock that she consult a myotherapist for treatment in the wake of her motor vehicle accident was a reasonable recommendation. It would appear that Mr Anderson’s treatment was of benefit to the Applicant for a period after the accident but that she herself has decided to cease it because she considered, after a discussion with Mr Kewish, that it was not substantially different from the physiotherapy she was receiving from him. The Tribunal notes that the myotherapy treatment appears not to be goal-driven in the sense of improving Mrs Sincock’s overall medical condition and accepts her concession that this treatment is no longer of benefit. Although the decision related to physiotherapy treatment, the Tribunal finds the reasoning in Re Popovic and Comcare [2000] AATA 264 (Popovic) persuasive. At [28] it found:In relation to the applicant’s claim for physiotherapy treatment expenses, in our view there is no role for passive physiotherapy in the applicant’s current treatment regime. The physiotherapy he was having could not improve him in the long term, has limited, if any, short term benefit, and may in fact be contra-indicated. Any therapeutic benefit he received was small and short-lived. The Tribunal concludes the myotherapy treatment is no longer reasonable treatment within the bounds of section 16 of the SRC Act. There is no evidence before the Tribunal, including from the Applicant, that this therapy has had continuing beneficial effects since the decision of May 2016. The reviewable decision 2016/4661 will be affirmed. In terms of the physiotherapy treatment, there is a lack of clarity in Dr King’s 1999 report. He records that Mrs Sincock suffered from a soft tissue injury to her cervical spine and to her shoulders in 1996 and then goes on to conclude that these conditions are, in his opinion, of a permanent nature. Dr King does not explain how he came to that conclusion except for the statement “in view of the lapse of time since the accident in question”. Dr King further is of the view that, although he notes x-rays reveal “very minor features of disc degeneration” he did not think this condition contributes in any way to the symptoms. The Tribunal is not medically qualified and does not derogate from Dr King’s conclusions except to say it is regrettable that he diagnosed the injuries from the car accident as soft tissue injuries (the same diagnosis others and most recently Mr Kelman subsequently made), but does not elaborate on why he thought this pathology, by itself, caused the Applicant’s back pain some three years on.