Dr. Eric VanderWerff. D.C. v. the Travelers Indemnity Company of Connecticut and Texas Department of Insurance-Division of Workers' Compensation and Commissioner Ryan Brannan, in His Official Capacity
This case concerns an appeal by Dr. Eric Vanderwerff, a chiropractor, against the judgments favoring Travelers Indemnity Company of Connecticut and Commissioner Ryan Brannan. Dr. Vanderwerff was denied full reimbursement for medical services provided to a workers' compensation claimant, as he was not part of Travelers' healthcare network. He argued that the claimant was not properly notified of network requirements under Texas Insurance Code Section 1305.451, specifically challenging whether a web link to a list of providers constituted adequate 'written notice'. The Fifth District Court of Appeals in Dallas, Texas, affirmed the trial court's judgments, holding that an electronic link satisfies the statutory requirement for 'written description,' particularly as the Texas Administration Code allows electronic format notice with an available paper version. The court also dismissed Dr. Vanderwerff's other declaratory judgment claims, reiterating that these issues were not properly exhausted through administrative remedies or fell outside the court's jurisdiction.