What is the test for determining the appropriate award for the cost of future care?

The test for determining the appropriate award for the cost of future care is an objective one based on medical evidence. For an award of future care: (1) there must be a medical justification for claims for cost of future care; and (2) the claims must be reasonable. Although it is unnecessary for a physician to testify that each and every item of care claimed is medically necessary, there must be an evidentiary link between the medical assessment and the care recommended by a qualified health care professional such as an occupational therapist or rehabilitation consultant: Milina; Gignac v. Rozylo, 2012 BCCA 351.

In addition to being medically necessary, future care costs must be justified because they are likely to be incurred by the plaintiff. The award of damages is thus a matter of prediction as to what will happen in the future. If a plaintiff has not used a particular item or service in the past it may be inappropriate to include its cost in a future care award: Izony v. Weidlich, 2005 BCSC 1315.