Parkview Hosp. v. Frost — Mar. 2016 (Summary)

DISCOVERY AND ADMISSIBILITY

Parkview Hosp. v. Frost
No. 02A03-1507-PL-959 (Ind. Ct. App. Mar. 14, 2016)

The Indiana Court of Appeals held that evidence of discounts provided to patients who either have private health insurance or are covered by government healthcare reimbursement programs is relevant and admissible evidence regarding the determination of reasonable charges under the Indiana Hospital Lien Act (“Act”).  Under the Act, a patient may contest the lien or the reasonableness of the charges by filing a motion to quash or reduce the claim in the court where the lien was perfected.  The court upheld a lower court order denying the hospital summary judgment.  The hospital had argued that because the patient agreed to be responsible for full charges as stated on the hospital’s charge-master, the patient had agreed that those charges were reasonable.