The claimant disputed his entitlement to a partially approved OCF-18 for psychological treatment. The only issue between the parties was the hourly rate for the service provider for the psychological services. The insurer approved the treatment plan at the rate of $99.75 per hour. The claimant argued that the service provider, who was a social worker, should be paid at the same rate as a psychologist ($149.61 as per the Professional Service Guidelines). The insurer disagreed, as the service provider did not have the experience or specialized training in psychotherapy or cognitive behavioural therapy and did not administer same to the claimant. Adjudicator Watt noted that social workers can provide psychotherapy services, and that psychotherapists may be paid at the psychologist rate in certain situations – for example, where the psychotherapist has a high level of experience/education or where the psychotherapist charges a rate in their non-MVA related practice that is the same or higher than the rate applicable psychologists in the Guideline. However, Adjudicator Watt found that the rate approved by the insurer was appropriate and reasonable, as he was provided with no evidence as to the qualifications of the service provider nor what hourly rate she charged in private practice.
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