AMERICAN MOBILE HEALTH SERVICES, INC., A/A/O TANIA JIMENEZ v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY

CourtDistrict Court of Appeal of Florida
DecidedFebruary 16, 2022
Docket21-0222
StatusPublished

This text of AMERICAN MOBILE HEALTH SERVICES, INC., A/A/O TANIA JIMENEZ v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY (AMERICAN MOBILE HEALTH SERVICES, INC., A/A/O TANIA JIMENEZ v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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AMERICAN MOBILE HEALTH SERVICES, INC., A/A/O TANIA JIMENEZ v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, (Fla. Ct. App. 2022).

Opinion

Third District Court of Appeal State of Florida

Opinion filed February 16, 2022. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D21-222 Lower Tribunal Nos. 20-207 AP, 13-23477 SP ________________

American Mobile Health Services, Inc., a/a/o Tania Jimenez, Appellant,

vs.

State Farm Mutual Automobile Insurance Company, Appellee.

An Appeal from the County Court for Miami-Dade County, Christina Marie Diraimondo, Judge.

David B. Pakula, P.A. and David B. Pakula (Pembroke Pines); Corredor & Husseini, P.A., for appellant.

Birnbaum, Lippman & Gregoire, PLLC, and Nancy W. Gregoire (Fort Lauderdale); Kirwan Spellacy Danner Watkins & Brownstein, P.A., and Christopher L. Kirwan and R. Ryan Smith (Fort Lauderdale), for appellee.

Before LOGUE, SCALES, and GORDO, JJ.

LOGUE, J. American Mobile Health Services, Inc., as assignee of Tania Jimenez,

appeals a judgment entered after a jury verdict against American Mobile and

in favor of State Farm Mutual Automobile Insurance Company. The jury

found that American Mobile’s claim for x-ray and MRI services did not reflect

a “reasonable amount” under section 627.736(5)(a), Florida Statutes. 1 State

Farm’s expert below had argued that the amount of the charge was

unreasonable solely because it exceeded 200 percent of the allowable

amount under the Medicare Part B fee schedule. American Mobile

contended below and now contends on appeal that State Farm was

precluded from making this argument because State Farm had not adopted

the Medicare Part B fee schedule as a schedule of maximum charges under

section 627.736(5)(a)1. For the reasons explained below, we affirm. 2

1 For ease of reference, we cite to the current codification. At the time relevant to this lawsuit, however, the statutory language at issue currently codified at 627.736(5)(a), Florida Statutes (2021) was codified at 627.736(5)(a)1., Florida Statutes (2008) and the language currently codified at 627.736(5)(a)1., Florida Statutes (2021) was codified at 627.736(5)(a)2., Florida Statutes (2008). 2 The remaining issues raised on appeal are either conclusively resolved by our interpretation of Florida’s No-Fault Motor Vehicle Statute or do not warrant further discussion.

2 Factual and Procedural Background

American Mobile’s assignor, Tania Jimenez, was injured in a motor

vehicle accident in October 2008. In October 2013, American Mobile filed a

two-count complaint against State Farm, Jimenez’s insurer, seeking a

declaration of rights and alleging breach of contract for State Farm’s alleged

underpayment of Jimenez’s medical charges for x-ray and MRI services.

State Farm filed an answer and affirmative defenses, including, as pertinent

to this appeal, the defense that American Mobile’s charges for its services to

Jimenez were unreasonable.

In February 2017, American Mobile moved for summary judgment on

the issue of reasonableness. Attached to its motion, American Mobile

included an assignment of benefits executed by Jimenez, bills representing

the charges it submitted to State Farm totaling $3,220.00, and State Farm’s

explanation of review for reimbursements totaling $809.97.

In response to the motion for summary judgment, State Farm filed an

expert affidavit from Dr. Edward Dauer. Dr. Dauer opined that American

Mobile’s charges were unreasonable. Specifically, Dr. Dauer stated, “I do not

expect to receive reimbursement for my charges in amounts that exceed

200% of what Medicare allows as I believe amounts higher than 200% of

Medicare are unreasonable.” Dr. Dauer explained:

3 The basis for my opinion that any charge or payment in excess of approximately 200% of Medicare is unreasonable is because in the medical community, Medicare is considered to be an objective benchmark or ‘standard’ for determining a reasonable charge. 100% of the Medicare fee schedule has been adopted as the base level of reimbursement by most insurance companies. The Medicare fee schedule is used by most insurance companies to determine their market value of radiology services.

Dr. Dauer further opined that the payments by State Farm “were fair and

reasonable and should represent the maximum reimbursements in this

case.”

American Mobile argued that an insurance company may not rely on

the Medicare Part B Fee Schedule to determine the reasonableness of a

provider’s charges unless it specifically elects to do so in its insurance policy.

Therefore, American Mobile argued, State Farm failed to present an issue of

fact as to the reasonableness of American Mobile’s charges. The trial court

denied the motion for summary judgment and the case proceeded to trial.

After Dr. Dauer testified in accordance with his affidavit, the jury

returned a defense verdict for State Farm. American Mobile moved for a

directed verdict, again asserting that Dr. Dauer’s testimony that any charge

over 200% of the Medicare reimbursement rate was unreasonable was

4 insufficient under Florida law to create an issue of fact. The trial court denied

the motion for directed verdict and entered judgment in favor of State Farm.

Discussion

As background, we note at the outset that the statute at issue requires

insurers that provide personal injury protection to pay medical providers 80

percent of reasonable expenses for medical treatment provided to insureds.

§ 627.736(1)(a), Fla. Stat. Turning to the two provisions in controversy, the

statute allows providers to charge only a “reasonable amount” and gives

examples of evidence that may be considered to determine the “reasonable

amount.” § 627.736(5)(a), Fla. Stat. It also authorizes an insurance company

to adopt a maximum charge that it would reimburse based on various

schedules, including the participating physician’s schedule of Medicare Part

B. § 627.736(5)(a)1., Fla. Stat.

In this regard, the statute reads:

(5) Charges for treatment of injured persons.—

(a) Any physician, hospital, clinic, or other person or institution lawfully rendering treatment to an injured person for a bodily injury covered by personal injury protection insurance may charge the insurer and injured party only a reasonable amount pursuant to this section for the services and supplies rendered . . . . With respect to a determination of whether a charge for a particular service, treatment, or otherwise is reasonable, consideration may be given to evidence of usual and customary charges and

5 payments accepted by the provider involved in the dispute, and reimbursement levels in the community and various federal and state medical fee schedules applicable to automobile and other insurance coverages, and other information relevant to the reasonableness of the reimbursement for the service, treatment, or supply.

1. The insurer may limit reimbursement to 80 percent of the following schedule of maximum charges: ....

f. (I) For all other medical services, supplies, and care, 200 percent of the allowable amount under the participating physicians schedule of Medicare Part B.

§ 627.736(5)., Fla. Stat.

Different Florida circuit court appellate panels have issued conflicting

decisions on the question before us. Florida’s First Judicial Circuit, for

example, has held that an insurer is barred from doing what State Farm did

here. State Farm Mut. Auto. Ins. Co. v. Imaging Center of Pensacola, Inc.

a/a/o Anthony Perkins, 21 Fla. L. Weekly Supp. 979a (Fla. 1st Jud. Cir. App.

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AMERICAN MOBILE HEALTH SERVICES, INC., A/A/O TANIA JIMENEZ v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-mobile-health-services-inc-aao-tania-jimenez-v-state-farm-fladistctapp-2022.