The Supreme Court ruled today that a plaintiff in a personal injury case can present evidence of the undiscounted charges for medical bills, and the defense can present evidence of the amount the provider accepted as full payment.
The plaintiff was injured when she fell on the driveway of the apartment she was renting, and she sued the landlord. At trial, she proffered her medical bills of $1,919, and stipulated that her insurer had negotiated a reduction for payment in full at $1,350. The trial court barred her evidence of the undiscounted medical bills and limited her evidence of damages to the amount actually paid for the treatment.
The Supreme Court agreed that plaintiff should have been entitled to present evidence of the undiscounted bills (“Original bills are certainly evidence of the value that the medical providers themselves place upon their services”), and noted that, by statute, the bills are prima facie evidence of the reasonable value of the charges.
It disagreed, however, that the discount was a “collateral source” because the rule excludes “only evidence of benefits paid by a collateral source.” Since the amount of the discount was never paid by anyone, it did not constitute a collateral source. Therefore, the defendant was free to present evidence of the discount: “Because no one pays the negotiated reduction, admitting evidence of write-offs does not violate the purpose behind the collateral-source rule.”
The court concluded that “the fairest approach is to make the defendant liable for the reasonable value of plaintiffs medical treatment,” and that “both the original medical bill rendered and the amount accepted as full payment are admissible to prove the reasonableness and necessity of charges rendered for medical and hospital care.”
For more on this case, click here.
