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Below is a link to the Pennsylvania Superior Court opinion in State Farm v. Cavoto from November 21, 2011. The case deals with whether chiropractors may delegate adjunctive procedures under the Chiropractic Practice Act (CPA) and Pennsylvania Motor Vehicle Financial Responsibility Law (MVFRL).

The Superior Court panel holds that the two Acts allow such procedures to be delegated to unlicensed support personnel as long as such procedures are performed under the direct supervision of a licensed chiropractor. However, determinations must be made on a case by case basis where the court determines whether the procedure, or aspect of the procedure in question, requires formal training or education in the practice of chiropractic.

How many other stats allow this type of delegation?

Scott B. Cooper, Esquire

Schmidt Kramer PC
209 State Street
Harrisburg, PA 17101
(717) 232-6300 – Telephone
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