Physical Therapy Institute, Inc. v. Bureau of Workers' Compensation Fee Review Hearing Office, 108 A.3d 957

Claimant injured his back and received physical therapy; Physical Therapy Institute (PTI) billed Insurer (Selective) for multiple treatment dates.
Insurer denied payment asserting PTI did not actually provide the services—another entity (a Medicare Part B provider) did—and thus PTI’s reimbursement rate should be $0.00.
PTI submitted five fee review applications to the Bureau’s Medical Fee Review Section; the Section ordered payment (four in full plus interest; one reduced).
Insurer requested de novo hearings contesting the determinations, arguing PTI was merely a billing entity and not the provider.
The Hearing Officer dismissed Insurer’s hearing requests for lack of jurisdiction and vacated the Medical Fee Review Section’s determinations, relying on this Court’s prior decision in Selective Insurance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Bureau has jurisdiction to decide if PTI was the actual provider (vs. billing agent)	PTI: fee review was proper because applications challenged "amount of payment" ($0) and fee review is the provider’s only remedy for nonpayment	Insurer: identity-of-provider is a liability issue outside fee review jurisdiction and must be decided by a WCJ	Court: Bureau lacks jurisdiction to determine provider identity; the fee-review determinations were properly vacated (followed Selective Insurance)
Whether vacating Medical Fee Review determinations leaves PTI without remedy	PTI: vacatur allows insurers to evade payment by asserting fabricated provider-identity claims, leaving providers without recourse	Insurer: Selective Insurance is controlling; providers may seek other remedies (claimant petitions, WCJ proceedings, or civil actions)	Court: Agreed with Insurer; providers may pursue claimant-filed review/penalty petitions or other legal actions; fee review is not the proper forum for provider-identity disputes

Selective Insurance Company of America v. Bureau of Workers’ Compensation Fee Review Hearing Office, 86 A.3d 300 (Pa. Cmwlth.) (Bureau lacks jurisdiction to decide whether billing entity or provider actually furnished services)
Walsh v. Bureau of Workers' Compensation Fee Review Hearing Office, 67 A.3d 117 (Pa. Cmwlth.) (standards for appellate review of Bureau hearing officer decisions)