Wyatt v. Rescare Home Care, 2013 Del. LEXIS 591

Wyatt was employed by Rescare as a certified nursing assistant for several years, caring for Isaac, a dependent child with significant lifting transfers.
Wyatt experienced lower back pain onset on December 15, 2010 during a work-related transfer; she later underwent emergency evaluation and eventually spinal surgery.
The Board found Wyatt's injury to be a compensable industrial accident and awarded medical benefits, disability benefits, and attorney’s fees.
Rescare challenged the Board’s decision regarding causation and medical expenses, arguing non-compensability of most medical costs.
The Superior Court reversed the Board on causation but did not rule on all issues; the Delaware Supreme Court granted review on appeal.
The Delaware Supreme Court held that the Board’s causation finding was supported by substantial evidence and that only first-visit expenses to a non-certified provider are compensable under the statutory scheme.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the injury causally related to work based on substantial evidence?	Wyatt argues Board decision supported by Dr. Venkataramana and lay testimony; contrary medical opinions are insufficient.	Rescare contends insufficient evidence linking the injury to work; reliance on medical opinions that are not firmly tied to work event.	Board finding affirmed; injury proven to be work-related.
Are Wyatt's medical expenses for Dr. Venkataramana compensable under the Delaware Health Care Payment System?	All medically necessary treatments should be compensable; emergency/uncertified provider should be allowed where reasonable.	Non-certified provider expenses require preauthorization or fall within limited exceptions; most expenses are not compensable.	Board properly limited compensation to first-visit expenses under 2322D(b); other medical expenses not compensable.
Does the emergency-exception provision apply to the facts of this case?	Emergency exception should exempt those costs from standard preauthorization/certification rules.	Emergency exception does not apply because treatment occurred outside an emergency department or prehospital setting.	Emergency exception does not apply; only first-visit costs may be compensable.

General Motors Corp. v. Freeman, 164 A.2d 686 (Del.1960) (board-supported causation where credible lay and medical evidence align)
Steppi v. Conti Elec., Inc., 991 A.2d 19 (Del.2010) (board's fact-finding upheld when medical testimony favors claimant)
Perry v. Berkley, 996 A.2d 1262 (Del.2010) (medical expert testimony based on inaccurate history is inadmissible)
Diamond Fuel Oil v. O’Neal, 734 A.2d 1060 (Del.1999) (context on substantial evidence and credibility of medical testimony)
Progressive N. Ins. Co. v. Mohr, 47 A.3d 492 (Del.2012) (statutory interpretation of health care payments and reasonableness)
PHL Variable Ins. Co. v. Price Dawe 2006 Ins. Trust, ex rel. Christiana Bank and Trust Co., 28 A.3d 1059 (Del.2011) (treatment of certified vs. uncertified providers and presumptions of reasonable/necessary care)
Vanvliet v. D & B Transp., 2012 WL 5964392 (Del.Super.Ct.2012) (discussed but not included due to lack of official reporter citation)