Hawaii Revised Statutes

Haw. Rev. Stat. § 386-24 (2026)

Medical rehabilitation

✓ current as of July 2026

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§386-24 Medical rehabilitation. The medical services and supplies to which an employee suffering a work injury is entitled shall include such services, aids, appliances, apparatus, and supplies as are reasonably needed for the employee's greatest possible medical rehabilitation. The director of labor and industrial relations, on competent medical advice, shall determine the need for or sufficiency of medical rehabilitation services furnished or to be furnished to the employee and may order any needed change of physician, hospital or rehabilitation facility. [L 1963, c 116, pt of §1; Supp, §97-23; HRS §386-24; gen ch 1985]

Case Notes

Neuromonics device was "reasonably needed" for treating employee's work-related tinnitus in order for employee to attain the "greatest possible medical rehabilitation", where: (1) none of the three independent medical examiners retained by the employer had opined that the device was not reasonably needed or had any experience with the device; (2) the opinion of the doctor who recommended that employee be fitted with the device was based upon experience with the device and medical expertise specifically related to studying and treating diseases and disorders of the ear; and (3) the nature of employee's injury and employee's treatment history established a need to augment, albeit with a new method, fourteen years of unsuccessful strategies to treat employee's tinnitus. 136 H. 217, 361 P.3d 444 (2015).

Notes of Decisions

Cited in 5 cases, 1980–2015 · leading case: Tamashiro v. Control Specialist, Inc., 34 P.3d 16 (Haw. 2001).

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Tamashiro v. Control Specialist, Inc., 34 P.3d 16 (Haw. 2001). · cites it 4× “2000) (employer's obligation in event of work injury is to "furnish to the employee all medical care, services, and supplies as the nature of the injury requires" pursuant to HRS § 386-21 (emphasis omitted), and that under HRS § 386-24, "medical services and supplies .”

Bocalbos v. Kapiolani Med. Ctr. for Women & Child., 997 P.2d 42 (Haw. App. 2000). · cites it 2× “) In addition, HRS § 386-24 (1985) mandates that the “medical services and supplies to which an employee suffering a work injury is entitled shall include such services, aids, appliances, apparatus, and supplies as are reasonably needed for the employee’s greatest possible…”

Emp. Ben. Comm., Etc. v. Pascoe, 504 F. Supp. 958 (D. Haw. 1980). “§ 386-24, and vocational rehabilitation, Hawaii Rev.”

Emp. Benefits Comm. of Ret. Sys. of Hawaiian Tel. Co. v. Pascoe, 504 F. Supp. 958 (D. Haw. 1980). “§ 386-24, and vocational rehabilitation, Hawaii Rev.”

Pulawa v. Oahu Constr., Co., Ltd., 361 P.3d 444 (Haw. 2015). · cites it 6× “HRS § 386-24, 12 titled “[mjedical rehabilitation,” states that “[t]he medical services and supplies to which an employee suffering a work injury is entitled shall include such services, aids, appliances, apparatus, and supplies as are reasonably needed for the employee’s…”

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