“Reasonable And Necessary” Treatment: What Does It Mean?

Your automobile insurer is supposed to pay for all “reasonable and necessary” non-OHIP-covered medical treatment (up to specific monetary limits).  This includes things like:

  • Physiotherapy
  • Counselling
  • Occupational Therapy
  • Rehab Support
  • Chiropractic
  • Acupuncture
  • Massage Therapy and
  • Mobility devices

Treatment is important for any person’s recovery from injury.  Treatment can alleviate pain and increase function.

But, often automobile insurers will balk at paying for treatment, stating “that’s not reasonable and necessary”.  Injury victims and treatment providers are left wondering, what does “reasonable and necessary” really mean?

The case law has held that to be “reasonable and necessary”, treatment should:

  • Have identified, reasonable goals
    • The goals are being met to a reasonable degree
    • The overall costs (not just financial, but also time invested) of achieving the goals is reasonable taking into consideration both the degree of success and the availability of other treatment alternatives[1]

For treatment providers, it is important to state how the treatment meets the “reasonable and necessary” criteria.

Pain relief is one of the most common goals of treatment.  So, what about pain relief?  Is treatment that provides pain relief “reasonable and necessary”?  The answer is:  Yes

The relief of pain is a valid and recognized goal of health care professionals.  In some sad cases, it can be the only goal.  And, the case law has held that pain relief is “reasonable and necessary”.[2]


[1] Violi v. General Accident, FSCOAD, 2000

[2] Violi v. General Accident, FSCOAD, 2000

Duncan Macgillivray
Written by

Duncan is a founding partner of White Macgillivray Lester LLP in Thunder Bay and Lecturer at the Bora Laskin Faculty of Law, Lakehead University, teaching Insurance Law. Duncan has served injury clients all across Northwestern Ontario, from the Manitoba border in the west, to Greenstone in the east and all the way up north to Hudson’s Bay. Duncan is involved in his community, serving on the Board of Directors of the Brain Injury Association of Thunder Bay and Area from 2009 to Present (with 2010 to 2015 as President) and the Board of Directors of Thunder Bay Counselling Centre 2009 to 2015 (with 2011 to 2015 as Board Chair). Duncan is also involved in the legal community, sitting on the Board of Directors of the Ontario Trial Lawyers’ Association since 2015, Thunder Bay Law Association since 2012, and Co-Chairing the Thunder Bay Law Association’s Civil Litigation CLE programs.