State Farm Mutual Automobile Insurance Company v. Universal X Rays Corp.

The Third District reversed a county court judgment that had denied State Farm's inclusion of Medicare's Budget Neutrality Adjustment (BNA) in calculating PIP reimbursements under the statutory schedule of maximum charges, accepting Universal X Rays Corp.'s confession of error on that issue. The case also arose against the backdrop of a certified conflict between the Fourth and Sixth DCAs and the Third DCA on the "Limiting Charge" issue — which applicable Medicare source governs PIP payment calculations — but State Farm withdrew that argument, leaving the conflict unresolved. For insurance and PIP practitioners, the decision confirms that insurers electing the schedule of maximum charges under Section 627.736(5)(a)(1) may properly embed the BNA factor in their reimbursement formula.

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