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 treatment. And Dr. Achors had not referred her to a neck specialist on his own – the recommendation came only after receiving her letter.
The county then sent the doctor its own letter asking, among other things, whether the March 2025 work injury was more likely than not primarily responsible for the recommended neck evaluation. The doctor replied that he could not say.
That response was decisive. Under Tennessee law, an injured worker seeking to expand a claim at this stage must show she is likely to prevail on the merits. For treatment involving a body part not in the original injury, she must demonstrate to a reasonable degree of medical certainty that the work injury contributed more than 50% to the need for that treatment. A treating physician who cannot make that connection does not satisfy the standard.
Timing was also a factor. Tennessee's Workers' Compensation Appeals Board has held that when an employee significantly delays seeking treatment for a body part other than the one originally injured, a bare allegation is not enough to support the request for authorized medical care. The court considered the ten-month gap as a relevant factor in its analysis.
Judge Lisa A. Lowe found that Ray was not likely to prevail on entitlement to a neck evaluation at this time and denied her request for a panel of orthopedic physicians for neck treatment.
The order did draw one firm line in Ray's favor. The court confirmed she remains entitled to reasonable, necessary, and related treatment for her right shoulder with Dr. Achors, citing authority that an employer cannot unilaterally end medical benefits following a compensable work injury it has already accepted. The denial of the neck claim does not affect the shoulder.
The practical lesson for HR is this: when a claim expands to include a new body part months after the original accident, the question that matters is whether the treating physician can affirmatively link that new condition to the work injury. A conditional recommendation on a form the worker sent, without a direct medical opinion on causation, is not enough to carry that burden.
The case is Heather Ray v. Campbell County Sheriff's Department, decided by the Tennessee Court of Workers' Compensation Claims at Knoxville on June 4, 2026.
