Sometimes. Texas limits medical recovery to the amount actually paid or incurred (Civil Practice and Remedies Code § 41.0105), and the claimant must show the care was necessary and reasonable. Chiropractic, massage and acupuncture can be part of a recoverable claim when they treat injuries from the crash and the records show it.
The short version
- The paid-or-incurred rule governs the number. Only the sums really paid or owed for the care count toward medical damages (§ 41.0105).
- Necessity and reasonableness must be shown. A sworn statement can support a finding that the charge was reasonable and the service necessary, but it is not evidence that the crash caused them (§ 18.001(b)).
- Your own PIP may pay. Personal injury protection covers reasonable expenses for necessary medical services incurred within three years (Insurance Code § 1952.151).
- Records matter. In a 2014 federal case reported by ABC13, a Bryan chiropractic clinic owner was sentenced for conspiring to defraud auto insurers of more than $3 million.
- The filing deadline does not change. Suit still has to be filed inside two years (§ 16.003(a)).
Does a car accident claim cover chiropractic, massage or acupuncture?
Yes, in principle. A claim can include chiropractic, massage or acupuncture when the treatment was for an injury caused by the crash, the cost was actually paid or incurred, and the care was necessary and reasonable. Nothing in the statutes read for this article excludes these therapies by name, so the question is the record behind each bill.
The test in Section 41.0105 is the same for any medical bill: it looks at what was paid or incurred, not at the name of the therapy. If the insurer argues that you share the blame, our note on how comparative negligence is argued in Texas covers that step. Where more than one driver is responsible, liability in multi-car accidents is the next question. The underlying claim is a negligence claim, the subject of our note on what tort law means in a Houston crash case. It is paying damages the injured person can prove, and the medical part of those damages is limited by the rule in Section 41.0105, described below. The other categories of damages, such as lost wages and pain and suffering, are set out in our article on the damages available after a Texas car accident.
The treatment is only one piece. The crash report, the photographs and the first medical visit can help show when and how the injury began. The crash report is one of the first records to gather, and our step-by-step note on requesting the official crash record explains how. Photographs taken at the scene are covered in our note on which photos help a claim, and witness statements can corroborate the same timeline. The Houston car accident practice page covers the wider claim.
How much of a medical bill can a Texas claimant recover?
What was really paid or owed, not the amount billed. Civil Practice and Remedies Code § 41.0105 confines medical and health care recovery to those sums, and it sits on top of any other limit the law imposes.
The statute is short. It looks at who paid for care, not only at the figure printed on the statement. Our article on the fee side of a Houston claim is separate from this question. Whether a particular payment or write-off counts is for counsel to decide on the facts.
The table below lists the Texas rules that decide an alternative-care bill, with the section that sets each one.
| Question | Rule | Source |
|---|---|---|
| How much medical cost can be recovered? | Only what was really paid or owed for the care counts. | Civ. Prac. & Rem. Code § 41.0105 |
| What proof supports the charge? | An affidavit that the charge was reasonable and the service necessary, served on each other party. It is not evidence that the crash caused the treatment. | Civ. Prac. & Rem. Code § 18.001(b), (d) |
| Does your own PIP pay? | Reasonable expenses for necessary medical services, incurred not later than the third anniversary of the accident. | Ins. Code § 1952.151 |
| How much PIP must an insurer provide? | The required amount does not exceed $2,500 for all benefits, for each person. | Ins. Code § 1952.153 |
| Can the named insured decline PIP? | Yes, by rejecting the coverage in writing. | Ins. Code § 1952.152(b) |
Sources, read 16 October 2026 on the Texas Legislature’s official statutes site: Civ. Prac. & Rem. Code ch. 41, ch. 18, and Insurance Code ch. 1952.
Does my own PIP coverage pay for alternative treatment?
Possibly, if your policy includes personal injury protection and the care is a necessary medical service incurred within three years. The statute does not name chiropractic, massage or acupuncture, so the policy wording and the facts of the care decide it.
The statute describes PIP as paying “necessary medical, surgical, x-ray, or dental services, including prosthetic devices, and necessary ambulance, hospital, professional nursing, or funeral services” (Ins. Code § 1952.151(3)(A)). It is paid to the named insured, members of the household and any authorized operator or passenger, including a guest occupant of the insured vehicle.
PIP is a first-party coverage, which means it is paid by your own insurer rather than the at-fault driver’s. The statute does not require an insurer to provide PIP “in an amount that exceeds $2,500 for all benefits, in the aggregate, for each person” (§ 1952.153), so the PIP limit printed on your declarations page is the first number to check. A higher limit is a matter of the policy you bought. If the at-fault driver has no insurance, a different coverage applies, explained in our article on what happens when the other driver is uninsured. If the driver also left the scene, our note on what to do when the driver flees applies.
Our article on the attorney question in an insurance claim covers how first-party and third-party claims run side by side, and the stages a claim passes through are set out in order in a separate article.
How do you prove an alternative treatment was necessary and reasonable?
With a sworn affidavit, served on the other side in time, backed by records. Section 18.001 makes such a sworn statement enough evidence on price and necessity unless a counter-sworn statement is served. By its own terms the affidavit is not evidence of causation, so the medical link has to be shown separately.
The affidavit must be taken before an officer who can administer oaths, be made by the person who provided the service or by the person in charge of the records showing the service and the charge, and include an itemized statement of the service and charge (§ 18.001(c)). The party offering it must serve a copy on each other party by the earliest of three dates set in subsection (d).
The other side has a window to contest it. A counteraffidavit must be served by the earlier of 120 days after the defendant files its answer, the date the party offering it must designate experts under a court order, or the date the Texas Rules of Civil Procedure require that designation (§ 18.001(e)); subsection (e-1) sets a different timing where a provider first treats the claimant after the answer. The section also applies only to civil actions, which means it is a litigation tool. Before a suit is filed, the same proof is built through the records and the negotiation.
What goes into the file, and what an adjuster may ask a claimant to hand over, is covered in our article on the records question an adjuster raises. The statute above is the place a lawsuit gets its rules; the records are what fill them.
Why does documentation matter for chiropractic and acupuncture bills?
Because the paid-or-incurred rule and the sworn necessity statement both depend on records, and billing records were at the center of at least one Texas prosecution. In 2014, the former owner of a Bryan chiropractic clinic was sentenced to nearly seven years in federal prison for conspiring to defraud automobile insurance companies of more than $3 million, according to ABC13 Houston.
The case concerns one clinic in Bryan, Texas. It is not evidence about any clinic in Houston today, and it says nothing about the honest providers whose records are in order.
The practical point is the same for every provider: records that show the complaint, the visit, the treatment and the charge, in an order a reviewer can follow. We discuss what a settlement needs to show in our piece on speaking with an adjuster before you have a lawyer, and the damages categories an adjuster will value in our article on what drives the value of a Houston car accident claim.
What records make an alternative treatment claim easier to prove?
The first-visit note, each treatment note, the referral history and every itemized bill, all describing the same injury. Each entry should tie a visit to a complaint from the crash, say what was done and what it cost, and show who paid. Section 18.001 requires the sworn version to carry an itemized statement of each service and charge.
Start with the first visit. A note written soon after the crash that describes the pain, where it is, and how it limits daily activity is an important early record. Keep the imaging and referral records from any physician, the session notes from the alternative provider, and any change in condition the provider wrote down.
Keep every bill and every payment record, including statements from a health plan or an insurer that paid part of a charge. Those records are what the paid-or-incurred rule looks at under Section 41.0105.
What if the treatment was for an injury you had before the crash?
Treatment for an old injury can still be part of a claim, but the records have to separate the condition as it was from the harm the crash caused. That is a proof question for the medical records, and it is the subject of our article on pre-existing conditions made worse by a crash.
A claimant may see a chiropractor or massage therapist for a back or neck that was already sore before the crash. The earlier records matter in that situation. A treating provider’s statement about what changed after the crash, and when, is the kind of evidence a claim has to show. Our article on how aggravation is proved in Texas sets out that comparison in more detail.
How do I start a claim that includes alternative treatment?
Start by gathering every bill, record and payment statement you have, along with the dates of each visit, and then book a consultation. A lawyer can read the records against the crash report and tell you what is missing, so the treatment is tied to the collision on paper from the start.
The personal injury page lists the case types the firm takes. Bring the crash report if you have it, a list of every provider you have seen since the crash and the dates, and any letter from an insurer. The case evaluation checklist lists the rest.
For a crash inside the city limits, the Houston Police Department’s public information page says a crash report takes 5 to 8 days of processing before it is available, and that a request needs at least two identifying details such as the date and location of the crash.
Fees are explained in our article on the fee side of a Houston claim, so the question does not have to be settled on the phone.
The filing window runs whatever the treatment, so a claim that includes alternative care still has to be filed within two years (Civ. Prac. & Rem. Code § 16.003(a)). Our Sugar Land article on the filing window after a crash walks through the same deadline with local examples, and the timeline article covers the timing from there.
You can also reach us through our contact page, or read about what to do after a car accident before the consultation.
Frequently asked questions
Should I see a chiropractor after a car accident?
Whether to see a chiropractor is a medical decision that a doctor should make with you. The legal question is different: the care has to be necessary, reasonable and caused by the crash for the bill to be recoverable, and the records should show that.
Can you go to a chiropractor after a car accident?
Yes. The statutes read for this article do not bar chiropractic care after a crash. The bill still has to be for an injury from the crash, actually paid or incurred, and documented.
How long after a car accident should I see a chiropractor?
The statutes read for this article set no waiting period for starting treatment. The records still have to link the visits to the crash, so an early first visit that describes the injury is the stronger record.
Will insurance pay for massage therapy after a car accident?
Possibly. Your own PIP can pay reasonable expenses for necessary medical services if the policy includes PIP, and a third-party claim can include the medical cost, limited to the amount actually paid or incurred. Counsel should review the policy and the bills.
How long do I have to wait for massage after a car accident?
No statute read for this article sets a waiting period. Massage that is part of a claim should be recommended or documented by the treating provider, with the reason for each session written in the record.
A claim that includes alternative treatment can be raised through the contact page.
About the authors
Sam A. Maida, Jr.
Owner and Managing Attorney
Sam A. Maida, Jr. has represented injured Texans in the greater Houston area since the firm opened in 1993.
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Bernard G. Johnson III
Litigation Managing Attorney
Bernard G. Johnson III is a board certified trial lawyer licensed in Texas since 1996 and a graduate of South Texas College of Law.