Insurer off hook for medical costs for worker’s travel to visit family

March 20, 2026

A Florida appellate court on Wednesday ruled that the costs associated with a tetraplegic worker’s travel to visit family out of state did not qualify for coverage as medical benefits.

As documented in Purple Pride Inc. v. Burgess, the man worked for Purple Pride Inc. He suffered injuries in a work-related motor vehicle accident in 2019 that left him tetraplegic. Burgess now requires around-the-clock attendant care.

The insurance provider for Purple Pride accepted liability for his injuries and has paid for attendant-care services in Atlanta, where he now resides. In 2024, he filed a petition for benefits seeking attendant care and other medical benefits for a trip he intended to take to visit family in New York.

Specifically, he sought benefits for the extra cost of traveling attendants, including their overtime pay and accommodations, and the extra cost of renting a lift, commode chair and other durable medical equipment.

He also supported his request with testimony from his psychotherapist that the trip was medically necessary in that it could improve his depression and anxiety symptoms.

The insurer denied payment, characterizing the trip as a personal vacation.

A judge found that the trip to New York to visit family was not medically necessary, as it was not to identify or treat an illness or injury. However, the judge ruled that the insurer had to cover the costs of travel, since the insurer conceded that he needed around-the-clock care and medical equipment as a result of the accident.

The judge reasoned that the insurer should cover the costs no matter where the man went, as industry “is responsible for what industry causes.”

The Court of Appeal for the 1st District of Florida said employers are obligated to furnish only medically necessary remedial treatment, care and attendance to an injured employee, which means medically necessary “constitutes the general defining term under which all compensable benefits awarded” must fall.

The court said Florida case law has recognized a distinction between “travel that is medically necessary and travel that merely improves a claimant’s quality of life.”

Quality-of-life travel has included visits to the movies, the mall, the park and the grocery store, the court said. It also included transportation to a parent’s funeral.

Basically, any “transportation other than to a doctor” reflects on quality of life rather than medical necessity and is “generally considered gratuitous and not compensable,” the court said.

“Here, because the JCC concluded that claimant’s proposed trip to New York was not medically necessary, the trip — at best — could only be categorized as travel to improve claimant’s quality of life,” the court said. “The Legislature has not included such quality-of-life travel within the ambit of medical benefits available under the Workers’ Compensation Law.”

Accordingly, the court concluded that it was an error for the judge to grant benefits for a trip that he determined was not medically necessary.