There have been numerous reports of Workers Compensation paying for a hot tub for physical therapy. Workers’ Compensation is required to provide necessary medical treatment for a compensable injury, including any appliances prescribed by the claimant’s treating physician.
The argument being made in that if one is disabled enough to require hot tub therapy, it is most likely that the individual does not have the capacity to open the cover. Additional argument has been made for chair assistance for entry and exists.
A source for information is the Workers Compensation Insurance forum.