What is the current state of the law on chiropractic and massage treatment?

Violi involved ongoing chiropractic and massage treatment with goals of pain relief and maintaining the applicant’s level of functioning. There, Director’s Delegate Draper,[4] in dismissing the appeal, approved the principle that pain relief is a legitimate goal of treatment, and noted that in some extreme cases, pain relief might be the only goal. He also noted that, more typically, pain relief will be part of “a broader treatment or rehabilitation strategy”. He cautioned that “evaluating the effectiveness of any treatment is important, especially in determining whether it should continue over a lengthy period,” and approved the approach taken by Arbitrator Sapin in Amoa-Williams v. Allstate Insurance Co. of Canada that “pain relief measures should not encourage an inappropriate or indefinite dependency, or interfere with other aspects of rehabilitation.”[5]