MRI Associates of Tampa, Inc. v. State Farm Mutual Automobile Insurance Co.
Medical providers, as assignees of PIP benefits, argued that State Farm's policy adopted an unlawful 'hybrid' reimbursement methodology by referring both to the statutory reasonableness factors in section 627.736(5)(a) and to the schedule of maximum charges in section 627.736(5)(a)1. The Florida Supreme Court held that the 2013 PIP statute does not make those two approaches mutually exclusive: the permissive language of the 2012 notice provision ('may limit payment') shows the schedule of maximum charges is an optional cap, not an exclusive methodology. State Farm's policy clearly and unambiguously elected the schedule, and the Court approved the Second District's result.
Key facts
- MRI Associates of Tampa, Inc., a medical provider and assignee of PIP benefits, sued State Farm Mutual Automobile Insurance Co. over the insurer's reimbursement methodology for medical services.
- State Farm's policy limited PIP reimbursements by reference to both statutory reasonableness factors and a schedule of maximum charges, capping payment at 80% of the schedule; the provider argued this 'hybrid' approach violated Florida's PIP statute.
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Why it matters
This is the Florida Supreme Court's first construction of the post-2012 PIP notice provision and it resolves years of litigation over the 'unlawful hybrid methodology' theory that PIP providers had used to defeat… — full analysis with a trial
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