At some point in most Minnesota workers’ compensation claims, a doctor will say you have reached “maximum medical improvement,” or MMI. Many injured workers are told, or assume, that this means the insurance company no longer has to pay for treatment. A July 2026 decision from the Minnesota Workers’ Compensation Court of Appeals (WCCA) makes clear that is not the law. Mottaz & Sisk Injury Law represented the injured worker in that appeal.
What Is MMI?
MMI is the point where your condition is not expected to improve significantly with more treatment. It does not mean you are healed. It does not mean you are pain-free. It simply means your recovery has leveled off.
MMI matters most for wage loss. Under Minnesota law, temporary total disability (TTD) benefits generally end 90 days after the insurer serves the MMI report, unless you have returned to work or are in an approved retraining plan. MMI also often triggers a permanent partial disability (PPD) rating.
The Berg Decision
In Kathryn Berg v. Spartan Nash Distribution Center (W.C.C.A. July 1, 2026), the compensation judge denied the employee’s claim for medical treatment. Our firm appealed on Ms. Berg’s behalf, and the WCCA reversed, finding that decision unsupported. The court’s published summaries make three important points:
1. MMI alone is not a basis to deny care. The court held that a finding of MMI, without more, does not justify denying otherwise reasonable and necessary medical treatment.
2. Treatment that is helping is evidence that it is reasonable. The court found that a ruling that treatment was not reasonable or necessary was unsupported. The medical opinions on the treatment had been rejected, and the employee’s records showed continuing improvement with no reference to negative outcomes.
3. Lawyer arguments are not medical evidence. The court explained that an attorney’s argument about whether treatment is reasonable does not count as evidence on its own, apart from the medical record. What matters is what the medical records and expert opinions actually say.
What This Means for You
You may still need treatment after MMI. Many people need ongoing physical therapy, injections, medication, chiropractic care, or follow-up visits to stay functional and keep working. Reaching MMI does not take that away.
Your medical records are your best evidence. If your treatment is helping, make sure your provider writes it down. Notes showing less pain, better sleep, more movement, or an improved ability to work and do daily tasks are powerful.
Tips for Keeping Your Treatment Approved
- Be specific with your doctor about how treatment helps. “I can now lift my grandchild” or “I can work a full shift” is more useful than “I feel a little better.”
- Ask your provider to document your progress and functional gains.
- Keep going to appointments. Gaps in care are often used to argue treatment is unnecessary.
- If the insurer denies treatment, do not simply give up on care your doctor recommends.
What to Do If Treatment Is Denied
When an insurer refuses to pay for medical care, the dispute can be brought to the Department of Labor and Industry (DLI) for an administrative conference or to the Court of Administrative Hearings (CAH). Insurers must give a specific reason for refusing to pay for disputed treatment and can be penalized if they do not. A written report from your treating doctor explaining why the treatment is reasonable and necessary is often the deciding factor.
We Fight for Your Medical Care
Mottaz & Sisk Injury Law handles medical disputes, from administrative conferences to appeals before the WCCA. We represent injured workers across Minnesota from our offices in Coon Rapids, Shakopee, St. Cloud, and Woodbury. We work on contingency and do not bill clients for costs. Call 763-421-8226 or contact us for a free consultation.
Past results: The outcome described above does not guarantee a similar result in any other case. Every case is different and depends on its own facts and law.
Disclaimer: This content is for informational purposes only and is not legal advice. Every case is unique, and results may vary. Consult an attorney about your specific circumstances.


