Doe v. HCA Health Services of TN

CourtCourt of Appeals of Tennessee
DecidedAugust 27, 1999
Docket01A01-9806-CV-00306
StatusPublished

This text of Doe v. HCA Health Services of TN (Doe v. HCA Health Services of TN) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe v. HCA Health Services of TN, (Tenn. Ct. App. 1999).

Opinion

IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE FILED August 27, 1999 JANE DOE and her husband ) JOHN DOE, on their behalf, ) Cecil Crowson, Jr. and on behalf of all other persons ) Appellate Court Clerk similarly situated, ) ) Plaintiffs/Appellees, ) Appeal No. ) 01-A-01-9806-CV-00306 VS. ) ) Davidson Circuit HCA HEALTH SERVICES OF ) No. 92C-2041 TENNESSEE, INC., d/b/a ) HCA DONELSON HOSPITAL, ) ) Defendant/Appellant. )

APPEALED FROM THE CIRCUIT COURT OF DAVIDSON COUNTY AT NASHVILLE, TENNESSEE

THE HONORABLE HAMILTON V. GAYDEN, JR., JUDGE

G. GORDON BONNYMAN, JR. 203 Second Avenue, North Nashville, Tennessee 37201

RALPH I. KNOWLES 1355 Peachtree Street Atlanta, Georgia 30309

JOHN A. DAY KATHRYN BARNETT 150 Fourth Avenue, North Nashville, Tennessee 37219 Attorneys for Plaintiffs/Appellees

H. LEE BARFIELD, II JAMES O. BASS, JR. ROBERT E. COOPER, JR. E. CLIFTON KNOWLES 2700 First American Center Nashville, Tennessee 37238-2700 Attorneys for Defendant/Appellant

AFFIRMED AND REMANDED

BEN H. CANTRELL, PRESIDING JUDGE, M.S.

CONCUR: CAIN, J. COTTRELL, J. OPINION This deceptively simple contract question may be like the cloud “about

the size of a man’s hand”1 that produced a great storm. At issue is whether a patient’s

promise to pay a hospital’s “charges” incorporates by reference the hospital’s secret,

proprietary list maintained for billing purposes. The Circuit Court of Davidson County

held that the promise did incorporate the list by reference, but held, nevertheless, that

the charges had to be reasonable. We concur in the result reached by the trial court

but on a different basis. Therefore we affirm.

I.

Jane Doe sought admission to a Donelson hospital for a medical

procedure. She was covered by insurance through her husband’s employer, and she

signed a form, furnished by the hospital, pertaining to the payment of her bill. We

reproduce it here in its entirety:

I certify that the information given by me is correct. I hereby authorize payment to HCA Donelson Hospital insurance benefits herein specified and otherwise payable to me but not to exceed the total charges for this hospital confinement. In applying for payment of [sic] under Title XVIII or Title XIX of the Social Security Act, I request payment of authorized benefits to be made on my behalf. I understand I am financially responsible to the hospital for charges not covered by this authorization. I further assume responsibility for payment of reasonable attorney/and/or collection fees in the event such costs are incurred in the collection of this debt.

Ms. Doe’s insurance paid its share of the bill and the hospital billed her

for the balance of $1,346.21. Ms. Doe and her husband asked for time to pay the

balance, but after six months, the hospital turned the account over to a collection

agency. The Does sued the hospital for a declaratory judgment that the hospital

breached its contract with them by demanding unreasonable charges for its goods

1 I Kings 18:44 (The Living Bible).

-2- and services.2 The complaint also sought to represent a class of plaintiffs similarly

situated.

The hospital filed an answer denying the material allegations of the

complaint and a counter-claim for the unpaid bill. The parties warily circled one

another for over four years. During that period the court did enter an order

conditionally allowing the action to be maintained as a class action. Finally, the

hospital moved for summary judgment on the ground that the “charges” Ms. Doe

agreed to pay on her admission referred to the hospital’s “charge master,” a

confidential list of the charges made by the hospital for all its goods and services.

The trial judge held that the use of the charge master did not violate the

Consumer Protection Act, did not amount to bad faith, and was not a breach of

contract. In a footnote the court also held:

The Court finds that the contract is not an open price contract, but a contract incorporating a price term by reference. Such contracts are valid: “If a promise indefinite as to price is capable of being made certain by an objective standard through extrinsic facts, it will be enforced.” Williston on Contracts §4:27; Vanderbilt v. Everett, No. 93C-2126. This does not, however, dispose of the issue of the reasonableness of the charges contained on the charge master, nor does it address the issue regarding the role of third party payors in establishing a meeting of the minds.

The court went on to say:

These issues, the practical necessity of maintaining a Charge Master list of over 7,000 items and services as a separate document from a patient/hospital contract, assignment of benefits, guarantee of payment, etc. underscores and illustrates the uniqueness of the field of hospital/health care endeavors when viewed through the lens of conventional contract law. Hospitals are concerned with delivering critical care to diverse and disparate types of patients and types of situations. This duty is given great weight by the court in addressing the

2 The complaint also alleged that the hosp ital violated the T ennes see C onsum er Protec tion Act, Tenn. Code Ann. § 47-18 -101, et. se q.; that the co ntract with the hospital was an adhesion contract; and that the hospital had violated a duty of good faith and fair dealing. All the various theories are based on the allegation that the hospital’s charges are unreasonable.

-3- parameters of what kind of evidence may be considered in arriving at a test of whether the prices of items or services are unreasonable, arrived at in bad faith, or are unconscionable. This ongoing duty of critical care is also being considered by the Court in so far as the class action designation is concerned, and the way damages, if any, are to be computed.

Simultaneous to delivery of this critical-care service to the public is the notion that the patients should not have to pay more than is reasonable under the circumstances. And the hospital should not be allowed to reap the benefit of an unfair bargain. In determining what is unreasonable or unconscionable or in bad faith, there are many considerations to be taken into account, assuredly some of which the court is yet to be made aware of. Nevertheless, the fact that a toothbrush costs substantially more at this defendant’s Summit hospital is not evidence in and of itself that there exists an unreasonable or unconscionable price or that the price was arrived at in bad faith. The evidence will reflect where the price is reasonable.

In this case, reasonableness may be shown by a combination of factors, including but not limited to, the overall profitability of the hospital, the inflating effect of indigent care, and the effect on competition of third party payors, i.e., insurance companies, having a much leaner financial obligation than it appears to the average person/patient, resulting in increased cost of services to the patient.

It seems to us that the court applied a hospital exception to the general

law of contracts. While finding that the contract incorporated a price term by

reference (presumably the charge master), the court, nevertheless, held that the

hospital’s charges had to be reasonable.3 The hospital urges us to return to orthodoxy

and hold that once the court finds that the charge master was incorporated by

reference, the inquiry is over.4

II.

3 The court was not breaking new ground in this approach. In Mercy Hosp ital v. Carr, 297 So.2d 598 (Fla.

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Doe v. HCA Health Services of TN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doe-v-hca-health-services-of-tn-tennctapp-1999.