When a claim adds a new body part, causation is everything – here's why
Tennessee court blocks a workers' comp neck claim after the treating doctor cannot confirm the work injury caused it.
Tennessee's workers' comp system just handed HR and risk managers a clear signal: a new body part added to an accepted claim needs more than a doctor's conditional recommendation to get funded.
Heather Ray hurt her right shoulder at work in March 2025. Her employer, the Campbell County Sheriff's Department, accepted the claim and authorized treatment with Dr. Kyle Achors, who performed surgery.
Ray did not report a neck injury at the time. About ten months into treatment, in January 2026, she told Dr. Achors she had developed neck pain. By March, the doctor noted he was uncertain why she had not progressed, given that her MRI showed her rotator cuff repair was intact. He ordered a functional capacity evaluation and anticipated placing her at maximum medical improvement – the point at which a patient's condition has stabilized as much as it will – at her next appointment.
The dispute turned on how Ray sought the neck evaluation. She sent Dr. Achors a letter asking him to check yes or no to the question of whether he would recommend she be seen by an orthopedic physician to assess her neck. He checked yes.
The county challenged that on several grounds. Ray's sworn affidavit described only a shoulder injury, not a neck injury. Her first neck complaint came about ten months after she began...
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