The Department of Labor changed the codes associated with physical therapy evaluations under the Commonwealth’s Worker’s Compensation Program. Because a schedule sets the payments to service providers like physical therapists, the alteration had to be characterized as new codes or simply a change to the prior one. A hearing examiner determined that the codes were merely a change in the description of the service. The Bureau of Workers’ Compensation filed exceptions. The Secretary of Labor and Industry sustained the objections and held that the alteration created new codes. The Pennsylvania Commonwealth Court reversed and held that the codes constituted adjustments and modifications of the existing codes.
