JCC Awards Moving-Expense Reimbursement as Medically Necessary After Heel Fracture

In Kristen Bell v. Palm Beach County School District/Davies Claims North America, Inc., OJCC Case No. 25-027711TAH, the claimant fractured her left calcaneus after falling from a classroom desk while preparing her room for the school year. Because she lived in a third-floor apartment with no elevator and was placed on strict non-weight-bearing status for about twelve weeks, she sought reimbursement for the cost of movers after relocating to a first-floor unit before surgery.

Judge Thomas A. Hedler rejected the employer-servicing agent's standing and jurisdiction defenses. The order found Bell had standing because she repaid her mother for the moving bill, and it held the JCC could treat the move as an awardable medical benefit when supported by competent medical testimony. Dr. James Clancy, the authorized treating surgeon, repeatedly testified that the first-floor move was medically necessary and that the compensable heel fracture was the major contributing cause of that need.

The JCC granted reimbursement of $1,493.00 for Lee's Moving Company, along with attorney's fees and costs, and also found the servicing agent waived any medical-necessity defense by failing to timely respond to Dr. Clancy's written recommendation. The order is a useful reminder that even when Chapter 440 does not list a benefit by name, a JCC may still award it if the record proves medical necessity and causation.

Source: Compensation Order