## Facts

- Robert J. Petrilla, a People’s Natural Gas employee, suffered a work-related injury on January 23, 1979, became paraplegic, and received total disability benefits.
- Petrilla required substantial daily home care, including catheterization, bowel training, transfers, dressing, exercises, and turning every two hours to prevent skin problems.
- Petrilla’s wife was trained at a treatment facility to perform home care and provided it for extended periods, but she was not a licensed health-care provider and did not provide the care under a physician’s supervision.
- Petrilla developed upper-extremity conditions (including bilateral carpal tunnel syndrome and a rotator cuff condition) related to the work injury, making transfers to a standard vehicle increasingly difficult.
- Petrilla’s treating physician prescribed a specially equipped van that would allow him to travel while seated in his wheelchair.
- The employer agreed it would pay for vehicle modifications but denied any duty to purchase the van itself and denied liability for payment for the wife’s services.

## Issues

1. Whether Section 306(f) of the Pennsylvania Workers’ Compensation Act requires reimbursement for home nursing care provided by an unlicensed spouse without medical supervision.
2. Whether a specially equipped van constitutes an “orthopedic appliance” (or compensable medical apparatus) under Section 306(f), requiring the employer to pay for the van itself rather than only necessary adaptive modifications.

## Decision

- The Commonwealth Court affirmed the Board’s order upholding denial of the claimant’s review petition.
- The employer was not required to reimburse Petrilla for nursing-type services provided by his wife because she was not a licensed practitioner and the services were not rendered under licensed supervision.
- The employer was not required to purchase or furnish a van; its obligation was limited to paying for reasonable, injury-related adaptive equipment or modifications to a vehicle.

## Legal Principles

- Section 306(f) authorizes payment for reasonable medical services and related items, including services rendered by duly licensed practitioners of the healing arts; it does not require payment for lay caregiving by family members when not provided by, or under the supervision of, licensed professionals.
- For mobility-related transportation needs, workers’ compensation may require payment for medically necessary adaptive devices and modifications, but not for acquisition of a motor vehicle itself.
- An “orthopedic appliance” under Section 306(f) may include discrete adaptive equipment needed because of the work injury, but a vehicle, considered as a general transportation item, is not treated as the compensable appliance.

## Conclusion

The court held that the Workers’ Compensation Act did not obligate the employer to pay for unsupervised home care performed by an unlicensed spouse or to buy a wheelchair-accessible van; the employer’s responsibility extended only to covered medical services and reasonable vehicle modifications required by the compensable injury.


Petrilla v. Workmen’s Comp. Appeal Bd. (People’s Nat. Gas), 692 A.2d 623 (Pa. Commw. Ct. 1997)