Case Update: Documentation Required for Medical Mileage Reimbursement

In this underlying case, the Maryland Workers' Compensation Commission ("WCC") ordered an Employer/Insurer to reimburse the Claimant for his medical mileage, even though he failed to document the actual travel costs. Claimant did not drive himself to any of the medical appointments, but instead either took a taxi, public transportation or obtained a ride from his mother. Claimant did not keep or submit any receipts pertaining to this travel upon submitting his request for reimbursement. Instead, the Claimant submitted forms indicating his round-trip mileage with no supporting documentation. Employer and Insurer appealed and the circuit court affirmed. Employer and Insurer then appealed the decision to the Maryland Court of Special Appeals.

On appeal, the Court held there was no reasonable rationale for requiring Employer/Insurer to pay medical mileage to a claimant that failed to document his travel expenses, particularly when this Claimant may not have incurred any travel expenses at all (i.e. if he was only driven by family members). The Court determined that Claimant was not entitled to medical mileage and reversed the decision below.

D.A.M. Carpentry Corp. v. Scurggs, No. 1614 September Term 2012 (Court of Special Appeals of Maryland, November 21, 2013)