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Florida Third DCA rules that physical therapy services provided by a licensed massage therapist do not qualify for personal injury protection (PIP) insurance reimbursement

On February 26, 2020, in Geico General Insurance Co. v. Beacon Healthcare Ctr. Inc. et al., No. 3D18-2030, the Florida Third DCA considered three consolidated appeals in which the Miami-Dade County Court had certified two questions of great public importance, both relating to whether physical therapy services (as distinguished from massage services) provided by a licensed massage therapist qualify for personal injury protection (PIP”) insurance reimbursement under Florida law. The PIP statute prohibits massage therapists from receiving PIP reimbursement. See § 627.736(1)(a)(5), Fla. Stat. (2019). The Third DCA concluded that while a licensed massage therapist can lawfully render physical therapy modalities pursuant to the exception set forth in the Physical Therapy Act, section 486.021(11), a health care clinic or provider licensed under part X Chapter 400 may not receive PIP reimbursements for physical therapy services enumerated in section 486.021(11) rendered by a licensed massage therapist employed by the clinic that is not “massage” as defined by section 480.033(3), because the plain language of the PIP statute precludes those reimbursements.

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