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.
Key facts
- Universal X Rays Corp. filed suit in county court in 2022 pursuant to an assignment of benefits from State Farm insured Danay Rodriguez, seeking PIP benefits for diagnostic medical tests performed after Rodriguez's automobile accident.
- State Farm's policy elected to limit PIP reimbursements to the statutory schedule of maximum charges under § 627.736(5)(a)(1) and, as authorized by § 627.736(5)(a), applied CMS coding policies and payment methodologies — including Medicare's Budget Neutrality Adjustment (BNA) — in its reimbursement calculations.
- +2 more key facts with a free trial
Holdings
- Under § 627.736(5)(a)(1), Fla. Stat., an insurer that elects the schedule of maximum charges may incorporate Medicare's Budget Neutrality Adjustment (BNA) as a factor embedded in the…
- +1 more holding with a free trial
Read the full opinion, holdings & search — free for 30 days
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision — in your hands.
- Search every tracked Florida decision in seconds
- Save, tag & file the cases that matter into your own library
- Read the full plain-English analysis and holdings
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.