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A recent unpublished decision from the New Jersey Division of Workers’ Compensation clarified the limits of its jurisdiction over medical provider claims arising from out-of-state workplace injuries.
In Meta Surgical Associates v. Six Continents Hotel, Inc. (December 22, 2025), the Court dismissed a Claim Petition for lack of jurisdiction on behalf of the Respondent, holding that because New Jersey did not have jurisdiction over the underlying workers’ compensation injury, it also lacked jurisdiction over the derivative medical provider claim.
Meta Surgical Associates v. Six Continents Hotel, Inc.
The dispute arose after a New Jersey-based medical provider sought additional reimbursement for services rendered to an injured employee whose workers’ compensation claim was filed and adjudicated entirely in New York. The injured worker received two procedures in New Jersey and also resided in New Jersey; however, the employer, employment relationship, injury, and workers’ compensation claim were all centered in New York. The provider, dissatisfied with reimbursement under New York’s fee schedule, filed a Medical Provider Claim (MPC) in New Jersey, seeking additional compensation.
The Rationale
Central to the Court’s reasoning was the principle that an MPC is derivative of the underlying workers’ compensation claim. Because New Jersey did not have jurisdiction over the underlying workers’ compensation claim, it likewise could not assert jurisdiction over the provider’s improper price adjustment claim.
Applying the multi-factor “Larson test,” the Court emphasized that nearly all relevant employment contacts were tied to New York—the location of the injury, employment, contract formation, and primary treatment. The mere fact that limited treatment occurred in New Jersey, or that the petitioner resided there, was insufficient to establish jurisdiction.
What Does This Mean for Employers and Carriers?
There has been very little guidance on when jurisdiction is appropriate for medical providers to bring claims regarding out of state injuries in New Jersey. While the Courts have been clear that there is no jurisdiction for medical providers without proof of underlying jurisdiction for the claimant’s case, this case reinforces the long standing rule that residency, alone, is not enough to confer jurisdiction. This decision adds another layer of defense for carriers to continue denying medical provider claims that arise out of injuries occurring in other states.
For more information about this decision or its impact on cross-border workers’ compensation claims, please contact a member of Chartwell’s Workers’ Compensation team.
