SAIF v. Swartz

To establish compensation for medical treatment, the accepted condition must be a material cause of claimant's current condition, and the treatment must be "for" that condition.

Petitioners (SAIF) claimed the medical review board erred in determining compensability standards under ORS 656.245. In 2007, claimant fell and landed on his tailbone. Insurers granted claimant’s lower back contusion treatment, but denied joint injection treatment because the pain did not relate to the ailment. A medical review board reversed the ALJ’s decision, basing its decision on ORS 656.245 that mandated insurers provide medical services for compensable injuries. Under SAIF v. Martinez, a medical treatment became compensable when the treatment was required as a material part of the injury. Accordingly, the issue before the Court of Appeals was whether the workplace injury was the material cause of claimant’s lower back contusion and whether the injections were for the resulting lower back pain. The Court held that substantial evidence supported the use of medical services for his injury, but there was a lack of substantial evidence demonstrating that the back pain was a material cause of the low back pain. Reversed.