State Farm v. Cavoto et al., 2011 Pa. Super. 250 (2011)

The Chiropractic Practice Act and the Motor Vehicle Financial Responsibility Law permit licensed chiropractors to delegate certain adjunctive procedures to unlicensed support personnel and seek reimbursement from insurers, as long as such procedures are performed under the direct supervision of a licensed chiropractor. However, such determinations must be made on a case-by-case basis, in which the trial court must evaluate whether the procedure, or an aspect of the procedure in question, requires formal education or training in the practice of chiropractic.

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