Begin v. Michigan Bell Telephone Co., 2009 ACO #39
The Appellate Commission remanded this matter back to the magistrate for a determination regarding what portions of the nurse case manager’s services constitute medical services under MCL 418.315(1) and pursuant to Lefko v Walter Toebe Construction Company, 2008 ACO #260. The magistrate concluded a nurse case manager was necessary in this case to avoid interruption in the plaintiff’s care. The magistrate must determine which portions of the nurse case manager’s services constitute medical services, and which constitute attendant care and, in so doing, allow for additional proofs regarding that determination. Key point: nurse case managers provide a covered benefit that is a combination of nurse care and attendant care, but the duties must be performed by a licensed professional (i.e. not a family member without training) to be covered.
