Court Finds that Rigorous PT Sessions are Necessary
May 6, 2026

ankle physical therapyPhysical Therapy can be one of the biggest costs in a workers’ comp claim but if it is properly managed it can also go a long way in helping a patient heal properly and in a timely manner. One employee for the University of Arkansas logged 100 PT sessions before the school said her treatments were done. She disagreed, saying she was still not recovered, and the school took their case to the Arkansas Court of Appeals.

Kym Tocci worked as a print-machine operator and hurt her back moving a case of envelopes in April of 2012. She was found to have a lower back sprain and her doctor recommended chiropractic treatment, PT, and an orthopedic consultation. Her physician, Dr. Thurman, continued her treatment with medicine and PT sessions. After the university denied her any more PT treatments in March of 2014, Tocci took her claim to an administrative law judge. She said her injury report allowed her to go to Trinity Rehabilitation for her PT but the school said she was now cleared to do only in-home therapy exercises. The judge agreed with Tocci. She provided reports from Trinity Rehabilitation that entitled her to PT treatments she could in no way perform at home, like receiving deep-tissue massages and aquatic therapy along with her other exercises. The University of Arkansas appealed.

The appellate court upheld the decision, since the school could not prove that her treatments were unreasonable. The school’s reviewing physician determined that Tocci did not need more physical therapy, but in Tocci’s treating doctor’s report it was noted that she was taking more medications as a result of feeling more pain from being unable to attend physical therapy. She did not think she was progressing like she used to. The court went by the extensive reports and testimony from her treating physician over the reviewing physician’s report.

Steve Flory was Tocci’s therapist at Trinity Rehabilitation and said he understands that in workers’ compensation cases there is often pressure to move the patient to in-home exercises as soon as possible, but with Tocci he really felt that she was greatly benefitting from the rehabilitation sessions and she was taking them extremely seriously in order to help her feel better.

Some insurers or employers argue that physical therapy, after a certain point, is just beginning to plateau the patient’s progress and is not really necessary. After reading the evidence and physician reports of this case, the extensive physical therapy really helped the patient and by stopping it she ended up on the backslide in terms of returning to full functionality. It may be an expense, but if it makes the patient feel better and can keep them pain-free instead of reaching for painkillers the expense is worth it.

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