American Select Insurance Company v. York Hospital c/o Wellspan Health (Bureau of WC Fee Review Hearing Office)

CourtCommonwealth Court of Pennsylvania
DecidedMarch 27, 2026
Docket1366 C.D. 2024
StatusUnpublished
AuthorWolf

This text of American Select Insurance Company v. York Hospital c/o Wellspan Health (Bureau of WC Fee Review Hearing Office) (American Select Insurance Company v. York Hospital c/o Wellspan Health (Bureau of WC Fee Review Hearing Office)) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Select Insurance Company v. York Hospital c/o Wellspan Health (Bureau of WC Fee Review Hearing Office), (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

American Select Insurance : Company, : Petitioner : : v. : No. 1366 C.D. 2024 : York Hospital c/o Wellspan Health : (Bureau of Workers’ Compensation : Fee Review Hearing Office), : Respondent : Submitted: December 8, 2025

BEFORE: HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE WOLF FILED: March 27, 2026

American Select Insurance Company (Insurer) petitions this Court for review of a September 19, 2024 order by Workers’ Compensation Fee Review Hearing Officer (Hearing Officer) Colleen Pickens denying Insurer’s Request for Hearing to Contest Fee Review Determination (Request) and directing Insurer to pay the remaining $98,967.61 on York Hospital’s (Provider) $142,460.54 total bill for treatment administered to the late Mary Frey (Claimant). Because Hearing Officer Pickens’ order is supported by substantial evidence in the record, we affirm. I. Factual Background The tragic incident giving rise to the instant case is not a matter of dispute between the parties. On the morning of July 8, 2022, Claimant was on the premises of Smith Auctioneers, LLC, her employer, when she fell down a flight of 13 steps and landed headfirst on a concrete floor. Insurer’s Br., App. A, FRHO Decision, Finding of Fact (F.F.) No. 3. Claimant was immediately taken to Provider’s trauma bay, where she presented at 9:02 a.m. with a four-centimeter gash on her left scalp and extreme hypertension. Id. Doctors assigned Claimant a Glasgow Coma Scale score of three, indicating non-responsiveness to all stimuli. Id. After a CT scan was conducted later that day, doctors discovered large subdural and subarachnoid hemorrhages and a skull fracture and diagnosed Claimant with a severe traumatic brain injury as well as hypoxic respiratory failure. Id., F.F. No. 4. Claimant underwent an emergency right-sided decompressive craniotomy; duraplasty; evacuations of two, large hematomas, and a temporal lobectomy. Id., F.F. No. 5. The postoperative diagnosis was of a “right-sided acute subdural hematoma with 1.2 cm of right-to-left midline shift and uncal herniation in the setting of extensive temporal and frontal contusions[,] with traumatic subarachnoid hemorrhage.” Id., F.F. No. 5(a). Claimant’s condition continued to deteriorate following the surgery until she died as a result of her injuries on the morning of July 10, 2022. Id., F.F. No. 7. On July 29, 2022, Provider sent Insurer a bill for the treatment and services rendered to Claimant from July 8, 2022, until July 10, 2022, requesting payment of $142,460.54. See Reproduced Record (R.R.) at 4a. On each of the itemized bill’s 11 pages, Provider had stamped the word “trauma” in capital letters. Id. at 5a-

2 15a. In response, Insurer’s representative, WellRithms,1 sent Provider a check for $43,492.43. See id. at 18a. In an accompanying Explanation of Review, WellRithms stated that it had identified $98,407.61 in reductions to the amount requested “based upon [g]overnment, [c]ommercial, and [p]rivate [p]ayer data.” Id. at 18a-19a. Among the adjusted payments listed by WellRithms was a $1,607.28 payment for anesthesia services, a $1,992.72 reduction from the $3,600.00 initially billed by Provider. Id. at 19a. In response, Provider submitted an Application for Fee Review to the Workers’ Compensation Bureau (Bureau) maintaining that the remainder of the full amount initially requested was still due from Insurer. R.R. at 1a-2a. Following an investigation, the Medical Fee Review section determined that the amount due to Provider was $98,967.61, plus 10% yearly interest. Id. at 206a. Insurer then submitted its Request to the Bureau, explaining that the “amount originally paid to Provider was consistent with Provider’s usual and customary charges for the services provided.” Id. at 527a. In addition, Insurer contended that Section 306(f.1)(10) of the Act2 as well as Section 127.128(a) of the Act’s Medical Cost Containment (MCC) Regulations3 unconstitutionally delegated the legislature’s authority. Id. II. Procedural Background A. Witnesses’ Initial Testimony The matter was initially assigned to Hearing Officer Derrick Coker, who held an evidentiary hearing on July 17, 2023. R.R. at 217a. Insurer first presented the

1 WellRithms describes itself as “a third-party payment integrity company that specializes in high-dollar, complex medical bills.” R.R. at 447a. 2 Act of June 2, 1915, P.L. 736, as amended, added by the Act of July 2, 1993, P.L. 190, 77 P.S. § 531(10). 3 Section 127.128(a) provides that charges for “[a]cute care” are exempt from the Act’s normal fee caps if the patient has an immediate life-threatening or urgent injury and the services are provided in an accredited trauma center or burn facility. 34 Pa. Code 127.128(a). 3 brief testimony of Dr. Ira Weintraub, who identified himself as WellRithms’ chief medical officer and a 38-year veteran orthopedic surgeon. Id. at 233a. When Provider objected to the presentation of Dr. Weintraub’s testimony as an expert on workers’ compensation medical billing, Insurer’s counsel explained that Dr. Weintraub was only testifying on “foundational issues” related to treatment. Id. at 234a. After summarizing the circumstances of Claimant’s injury, Dr. Weintraub was asked if he believed there was any dispute as to whether the care was properly defined as trauma care; Dr. Weintraub responded, “[n]ot at all.” Id. at 236a. Provider’s counsel had no questions for Dr. Weintraub on cross examination. Id. Insurer next presented the testimony of Jordan Weintraub, a WellRithms employee whom Insurer described as “an expert in medical bill review and analysis based on her experience in the field.” R.R. at 240a. Ms. Weintraub acknowledged that she did not hold a degree or any particular certifications in billing, bill coding, or auditing, but explained that she had served as WellRithms’ vice president of claims for approximately five and a half years, and that she had a total of nine years’ experience in medical bill review. Id. at 239a, 242a. Like Dr. Weintraub, Ms. Weintraub did not dispute that the care administered to Claimant was properly classified as trauma care. Id. at 254a. Regarding the billing dispute, Ms. Weintraub explained that WellRithms’ repricing of the amount due to Provider was based on three categories of data. R.R. at 245a. The first category consisted of cost transparency data that Provider, like all hospitals, is legally required to disclose regarding its charges for all services. Id. For WellRithms’ purposes, the most important information that WellRithms expected to find in the cost transparency data were charges arranged by diagnostic- related grouping (DRG), a number that catalogs services according to diagnosis and

4 treatment. Id. at 251a. Ms. Weintraub explained that the relevant DRG in this case was 955, the number representing a craniotomy for multiple significant trauma. Id. at 253a. However, Ms. Weintraub contended that Provider’s charges for DRG 955, or any other DRG, were absent from the file containing its cost transparency data. Id. at 246a. The second category consisted of charge information from Hershey Medical Center (Hershey), which Ms. Weintraub identified as the other level one trauma center closest to Provider’s campus.4 Ms. Weintraub recalled that the Hershey transparency data were garnered from a page on Hershey’s website, bearing the heading “Understanding Your Care,” which displayed Hershey’s gross charges for all DRGs. R.R. at 264a, 270a. Most relevantly, the Hershey data contained the gross and average charge for DRG 955, which is based on an 11.1-day average length of stay. Id. at 273a. Ms. Weintraub explained that WellRithms used that number to prorate the charges for a stay that was shorter or longer than the 11.1-day average. Id.

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Bluebook (online)
American Select Insurance Company v. York Hospital c/o Wellspan Health (Bureau of WC Fee Review Hearing Office), Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-select-insurance-company-v-york-hospital-co-wellspan-health-pacommwct-2026.