This paper presents a new empirical path loss model for wireless communication at 2.4 GHz above simulated human tissue. The model is valid for dipole antennas placed up to 5 cm above flat phantom tissue simulating muscle or brain, and for distances up to 40 cm. Simulation and measurement results showed excellent agreement. The study found that antenna height has a major influence on path loss, with path loss dropping quickly as height decreases. Models were developed to estimate path loss as a function of antenna height and distance for both muscle and brain tissue.