The insurer challenged the hourly rates claimed in one of the claimant’s treatment plans. The claimant submitted a psychological treatment plan, which sought entitlement to psychological treatment at an hourly rate of $149.61 per hour. The psychological treatment plan was to be provided by a registered psychotherapist. The insurer partially approved the treatment plan at a rate of $100.00 per hour. Adjudicator Norris held that claimant was not entitled to the higher hourly rate of $149.61 per hour. The Professional Services Guideline is silent as to the maximum hourly rate of a psychotherapist. Relying on the LAT’s decision in Baranov v. Aviva General Insurance, Adjudicator Norris held that the claimant did not met her onus to demonstrate that she is entitled to an enhanced hourly rate for psychotherapy services. Similar to this case, the LAT awarded a rate of $99.75 in Baranov for counselling, mental health and addictions treatment by a psychotherapist. Adjudicator Norris found that the claimant failed to provide relevant information to justify paying a higher rate, such as reference to the provision of cognitive behavioural therapy or other specialized psychotherapy treatment.
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