Lake Charles Memorial Hospital (Stephen Babin) v. Hobby Lobby Stores, Inc.

CourtLouisiana Court of Appeal
DecidedNovember 24, 2010
DocketWCA-0010-0261
StatusUnknown

This text of Lake Charles Memorial Hospital (Stephen Babin) v. Hobby Lobby Stores, Inc. (Lake Charles Memorial Hospital (Stephen Babin) v. Hobby Lobby Stores, Inc.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lake Charles Memorial Hospital (Stephen Babin) v. Hobby Lobby Stores, Inc., (La. Ct. App. 2010).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

10-261 consolidated with 10-262 and 10-263

LAKE CHARLES MEMORIAL HOSPITAL (STEPHEN BABIN)

VERSUS

HOBBY LOBBY STORES, INC.

************

APPEAL FROM THE OFFICE OF WORKERS’ COMPENSATION, DISTRICT 3 PARISH OF CALCASIEU, NO. 05-01207 SHELLY D. DICK, WORKERS’ COMPENSATION JUDGE

DAVID E. CHATELAIN* JUDGE

Court composed of Sylvia R. Cooks, J. David Painter, and David E. Chatelain, Judges.

AFFIRMED IN PART; REVERSED IN PART; RENDERED.

Thomas A. Filo Cox, Cox, Filo, Camel & Wilson, L.L.C. 723 Broad Street Lake Charles, Louisiana 70601 (337) 436-6611 Counsel for Plaintiff/Appellant: Lake Charles Memorial Hospital

* Honorable David E. Chatelain participated in this decision by appointment of the Louisiana Supreme Court as Judge Pro Tempore. John V. Quaglino Denis P. Juge Juge, Napolitano, Guilbeau, Ruli, Frieman & Whiteley 3320 W. Esplanade Avenue North Metairie, Louisiana 70002 (504) 831-7270 Counsel for Defendant/Appellee: Hobby Lobby Stores, Inc. CHATELAIN, Judge.

In these consolidated cases, a health care provider appeals the denial of its

claims that the employer of three workers’ compensation claimants underpaid charges

for medical treatment the health care provider rendered to the claimants and that the

underpayment was arbitrary and capricious, entitling it to penalties and attorney fees.

For the following reasons, we reverse the denial of the health care provider’s claims

and award penalties and attorney fees for the underpayment. We also affirm the

award of penalties and attorney fees for late reimbursement of the claims.

FACTS

In 2002 and 2003, three employees of Hobby Lobby Stores, Inc. (Hobby

Lobby) in Lake Charles were injured in the course and scope of their employment and

sought treatment for their injuries at Lake Charles Memorial Hospital (LCMH).

LCMH submitted bills for services it rendered to the employees of Hobby Lobby;

Hobby Lobby remitted payments which were less than the amounts set forth in the

Louisiana Workers’ Compensation Reimbursement Schedule (Reimbursement

Schedule), as provided in La.R.S. 23:1034.2, and more than sixty days after receiving

notice of the bills in derogation of La.R.S. 23:1201(E).

The reimbursement payments Hobby Lobby remitted were calculated pursuant

to the provisions of a Preferred Provider Organization (PPO) Hospital Agreement

LCMH had with CorVel Corporation (CorVel) and a Workers’ Compensation

Managed Care Service Agreement Hobby Lobby had with CorVel. In the PPO

agreement, LCMH agreed to provide hospital and physician services to CorVel

beneficiaries, such as Hobby Lobby’s employees, at “85% of billed charges,” “85%

of usual and customary rates,” or “85% of any applicable maximum allowable rate as

1 specified by the State, whichever is less.” Following receipt of Hobby Lobby’s

payments, LCMH filed disputed claims to recover “[u]nderpayment and/or late

payment of medical bills” and “penalties and attorney fees for arbitrary and capricious

handling” of each of the three employees’ claims.

The three claims were consolidated and tried. With regard to each of the three

claims, the workers’ compensation judge (WCJ) denied LCMH’s claims for

underpayment and penalties and attorney fees for Hobby Lobby’s arbitrary and

capricious handling of the claims but awarded $2000 in penalties and attorney fees

of $1000 because the reimbursement payments were “late.”

LCMH appealed, seeking reversal of the denial of its claims and an award of

penalties and attorney fees for Hobby Lobby’s failure to pay the full amount of its

claims. Hobby Lobby answered the appeal, seeking reversal of the penalties and

attorney fees for the late payment of LCMH’s claims.

ISSUES PRESENTED

LCMH’s assignments of error and Hobby Lobby’s answer present the

following issues for our consideration: (1) Did the WCJ err in dismissing LCMH’s

claims for underpayment? (2) If the WCJ erred in dismissing LCMH’s claims for

underpayment, was Hobby Lobby’s underpayment arbitrary and capricious, entitling

LCMH to penalties and attorney fees? and (3) Does a health care provider have a

claim for penalties and attorney fees for late payment of a claim for services

rendered?

2 DISCUSSION

PPO Discount

LCMH asserts that the WCJ erred in concluding that Hobby Lobby “made a

prima facie showing of a defense” to its claim of underpayment because LCMH

agreed in its PPO agreement with CorVel to accept “85% of any applicable maximum

allowable rate as specified by the state.” We agree.

This court has recently held that a PPO agreement, such as the one between

LCMH and CorVel, does not relieve an employer that has a separate agreement with

a disability management and cost containment service of its obligation to reimburse

health care providers in accordance with the Reimbursement Schedule in La.R.S.

23:1034.2. See Cent. La. Ambulatory Surgical Ctr., Inc. v. Payless Shoesource, Inc.,

10-86, 10-91, 10-92, 10-96, 10-97, 10-99, 10-100, 10-115, 10-117, 10-118 (La.App.

3 Cir. 7/28/10), ___ So.3d ___; Agilus Health v. Accor Lodging N. A., 09-1049

(La.App. 3 Cir. 3/10/10), 32 So.3d 1120, writ granted, 10-800 (La. 6/18/10), 38 So.3d

312. In Payless, ___ So.3d at ___, this court determined that a PPO contract which

“purports to reduce or relieve the employer’s liability for workers’ compensation

medical payments from the full amount of the Fee Schedule . . . flies in the face of the

language and purpose of the Act” because such reductions fail to consider the

interrelationship of the pertinent sections of the workers’ compensation statute and

the overall social legislative purpose of the act.

The interrelationship of La.R.S. 23:1033 and La.R.S. 23:1203 was considered

important in Payless and Agilus. Louisiana Revised Statutes 23:1033 provides that:

“No contract, rule, regulation or device whatsoever shall operate to relieve the

employer, in whole or in part, from any liability created by this Chapter except as

3 herein provided.” Thereafter, Section 1203(B) outlines the workers’ compensation

employer’s obligation to pay medical expenses; it states in pertinent part:

The obligation of the employer to furnish such care, services, treatment, drugs, and supplies, whether in state or out of state, is limited to the reimbursement determined to be the mean of the usual and customary charges for such care, services, treatment, drugs, and supplies, as determined under the reimbursement schedule annually published pursuant to R.S. 23:1034.2 or the actual charge made for the service, whichever is less.

In Payless, ___ So.3d at ___, a panel of this court found that Sections 1033 and

1203(B) and the Louisiana Workers’ Compensation Act (LWCA) “as a whole,

prohibit any contracts that would operate to relieve an employer of liability created

by the LWCA.” Agilus also determined that La.R.S. 23:1033 prohibits a PPO

contract from reducing an employer’s liability under the Louisiana Workers’

Compensation Act below what is provided in the Reimbursement Schedule.

Hobby Lobby urges that it is illogical to conclude that a health care provider

can reduce an employer’s reimbursement by charging the employer less than the

reimbursement schedule provides pursuant to La.R.S. 23:1203(B) but cannot achieve

the same end by agreeing to accept less by entering a PPO contract which does so.

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