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Court Backs Hospital In Insurer PIP Dispute

Leon County Judge John Cooper on June 30, 2022, in a screen grab from The Florida Channel.
Wikimedia Commons
The Florida Channel
Leon County Judge John Cooper on June 30, 2022, in a screen grab from The Florida Channel.

An appeals court Wednesday rejected an attempt by State Farm Mutual Automobile Insurance Company to gather a variety of information about how much a Palm Beach County hospital charges to treat injured patients. State Farm filed the case under the state's personal-injury protection laws for auto insurance.

Delray Medical Center treated two of State Farm's customers and sought so-called PIP payments from the insurer. State Farm questioned whether the charges were reasonable, arguing that the amounts were more than under Medicare billing rates, according to Wednesday's ruling by the 4th District Court of Appeal.

Ultimately, State Farm sought to obtain detailed information about the hospital's charges for the same types of care provided to the PIP patients.

That included seeking information about payments the hospital accepted for such care from Medicare, Medicaid, workers-compensation insurance, commercial insurance policies and uninsured patients.

A Palm Beach County circuit judge ruled against State Farm, finding that the request was "overbroad" and "extremely far-reaching." A three-judge panel of the appeals court agreed in Wednesday's eight-page opinion.

"State Farm asks us to interpret this statute to allow for the discovery of those documents that will determine, according to State Farm, whether the billing is reasonable when one considers the allowable charge under Medicare,'' said the opinion, written by Judge Spencer Levine and joined by judges Matthew Stevenson and Mark Klingensmith.

"Further, State Farm wants to compare what Delray Medical has negotiated with private insurance companies to determine reasonableness. This is beyond the plain language of the statute."