Applicant v. Allstate Insurance (18-006253)

The claimant sought entitlement to over $24,000 in catastrophic impairment rebuttal reports. The insurer argued that dispute was statute barred. Adjudicator Grant held that catastrophic impairment assessments are not “benefits” and therefore not subject to the two year limitation period. Adjudicator Grant concluded that the proposed assessments were reasonable and necessary, and were therefore payable. It was not a requirement that the assessments be proposed prior to the OCF-19 submission or prior to the insurer’s IE assessments being completed. A total of $2,000 per assessment was approved, and did not come out of the claimant’s medical benefits limits.