Background
Orville Peters injured his right hand while working as a master plumber for Portsmouth Plumbing Services in 2012. The Virginia Workers’ Compensation Commission awarded him disability benefits and lifetime medical benefits. In 2018, Peters, his employer, and its insurer entered a $159,000 lump-sum settlement. The Commission’s order stated that the employer and carrier remained responsible for authorized and necessary medical bills related to the injury through the date of the settlement order, but not afterward.
Peters later sought additional payment for allegedly underpaid medical bills from The Therapy Network for treatment provided in 2013 and 2014. The record contained conflicting information: Peters asserted balances of $6,879.90 and $6,971.10 at different times, while a 2016 provider statement showed a zero balance. The Commission rejected the claim without resolving whether any debt remained, reasoning that the settlement’s extinguishment provision barred the claim.
The Court’s Holding
The Court of Appeals reversed. It held that the settlement order did not extinguish Peters’s claim for authorized and necessary medical bills incurred before the order was entered. The order expressly preserved the employer and carrier’s responsibility for those bills, and its broader extinguishment language applied only subject to the obligations specifically preserved elsewhere in the agreement.
The court declined to decide whether appellate courts owe deference to the Commission’s interpretation of its own settlement orders. Even assuming deference applied, the Commission’s interpretation was unreasonable and contrary to the court’s binding decision in Northrop Grumman Shipbuilding, Inc. v. Wardell Orthopaedics, P.C. Because the Commission had made no factual finding about whether The Therapy Network was still owed money, the court remanded for the Commission to determine whether any qualifying debt remained and, if so, its amount.
Key Takeaways
- A workers’ compensation settlement preserving liability for authorized and necessary medical bills through the settlement date covers qualifying pre-settlement bills that remain unpaid.
- General language extinguishing claims does not override an express exception preserving responsibility for specified medical expenses.
- The Court of Appeals could not determine the unpaid amount itself because the Commission had not resolved the conflicting evidence, including a provider statement showing a zero balance.
Why It Matters
The decision reinforces that workers’ compensation settlement orders must be read as a whole and that expressly preserved medical-payment obligations cannot be erased by more general release language. Employers, carriers, claimants, and counsel should carefully distinguish between pre-settlement medical expenses that remain covered and post-settlement expenses that have been waived.
The ruling does not establish that The Therapy Network is owed money. It returns the case to the Commission for factual findings on whether any unpaid debt exists, leaving unresolved broader questions concerning the standard of review for settlement orders and a claimant’s ability to pursue a provider’s otherwise time-barred payment claim.