There are those injured workers who seek to maintain activities of daily living through "passive modalities" such as massage therapy, ostensibly saving the insurance company the cost of much more expensive treatment. More numerous are those insurance carriers who do not consider massage therapy to be "medical treatment" at all, and seek to avoid paying for such care—ironically at any costs. "Wouldn't we all love to stay home from work and get a massage," the cynical criticism goes.

Defense bias notwithstanding, massage therapy can play an important role in maintaining a certain quality of life while one is coping with a work injury. In the early stages, it can even promote a cure by stretching tissues, breaking down adhesions and reducing swelling in joints, allowing for quicker healing. The problem has always been that an injured worker's ability to have massage therapy covered by a workers' compensation carrier was dependent on the good will of the claims adjuster, as the laws in Pennsylvania have traditionally not recognized massage therapy as covered medical treatment, as such.

In the closing days of 2017, the Commonwealth Court provided a roadmap and, quite frankly, a gift to those injured workers who would choose massage therapy as their modality of choice in the case of Schriver v. Workers' Compensation Appeal Board (Pennsylvania Department of Transportation), No. 289 C.D. 2017.  The only issue in the case is whether the claimant's massage therapy expenses were reimbursable.