Benefits: Travel Expenses

Dostal v. Uninsured Employers' Fund [11/05/12] 2012 MTWCC 41 Respondent authorized the medical treatment for which Petitioner incurred and sought reimbursement for travel expenses.  Although Respondent argued that the travel expenses were not reasonable expenses, the Court concluded that since the medical treatment itself was reasonable, then the travel Petitioner undertook in order to avail herself of the approved medical treatment was likewise reasonable.

Vandervalk v. Montana State Fund [11/05/09] 2009 MTWCC 35 Section 39-71-701(1)(d)(ii)(A), MCA, excludes from reimbursement the first 100 miles of qualified automobile travel for each calendar month. Since Petitioner’s pertinent travel consists of a round trip of 26 miles approximately every 90 days, he is not entitled for reimbursement of this travel expense.
Vandervalk v. Montana State Fund [11/05/09] 2009 MTWCC 35 Section 39-71-701(1)(d)(i), MCA, provides only for reimbursement of expenses incurred in traveling to a medical provider for treatment of an injury. A claimant’s trips to and from a pharmacy to fill prescriptions are not reimbursable travel expenses under § 39-71-701(1)(d)(i), MCA.
Arneson v. Travelers Property Casualty [02/28/06] 2006 MTWC 7 Petitioner argued that in addition to reimbursement for travel expenses at the state rate, Respondent should pay for repairs to Petitioner’s car, including oil changes and a new windshield, which were necessary for his travel. The Court determined that the applicable statute allows only for reimbursement at the same rates as allowed for state employees, and Petitioner provided no evidence that state employees can claim such repairs as travel expenses.
Arneson v. Travelers Property Casualty [02/28/06] 2006 MTWC 7 Petitioner, relying on ARM 24.29.1409(1)(d), argued that in addition to reimbursement for travel expenses at the state rate, Respondent should pay for repairs to Petitioner’s car, including oil changes and a new windshield, which were necessary for his travel. The Court determined that the examples of reimbursable expenses listed in the subpart of the ARM upon which Petitioner relied were dissimilar to the expenses Petitioner desired to claim under its auspices.

Burnside Lund v. St. Paul's [1/14/03] 2003 MTWCC 2 Under the 1997 version of the Workers' Compensation Act, travel for medical care is reimbursed only if the travel is at the behest of the insurer, thus, travel for regular treatment is not reimbursable. 39-71-704(1)(d), MCA (1997).