Mid American Construction LLC v. Sandlin
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Marshall Sandlin, a laborer at Mid American Construction LLC, suffered an injury to his left foot during work. After an initial medical examination conducted by a physician chosen by Mid American's insurance carrier, Grinnell Mutual, Sandlin underwent another independent medical examination (IME) by a physician of his choosing. Sandlin sought reimbursement for the full cost of this second examination, as he believed the first examination's evaluation was too low.
The Supreme Court of Iowa had to decide whether an amendment to Iowa Code section 85.39(2) in 2017 limited an employee's reimbursement for an IME to only the cost of the impairment rating or included the full cost of the examination. The court held that the employee is eligible for reimbursement of the reasonable cost of the full examination to determine the impairment rating, not merely the cost of the impairment rating itself. The court interpreted the term "examination" as used in the statute to include review of medical records, physical examination, testing, and written report.
However, the court found that the commissioner's analysis of the physician's fee as reasonable was incomplete. While the commissioner considered the physician's written opinion about the reasonableness of his fee, the commissioner failed to analyze the typical fee charged for such an examination in the local area where the examination was conducted, as required by the 2017 amendment to the statute. Consequently, the court remanded the case for further fact-finding on the issue of the reasonableness of the fee based on the typical fee charged in the local area.
Thus, the Supreme Court of Iowa affirmed in part and vacated in part the decision of the Court of Appeals and affirmed in part, reversed in part, and remanded the judgment of the District Court.
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