Med. Mgmt. Group of Orlando, Inc. v. State Farm Mut. Auto. Ins. Co.,

Med. Mgmt. Group of Orlando, Inc. v. State Farm Mut. Auto.
Ins. Co.,
No. 5D01-1123 (Fla. Dist. Ct. App. Feb. 8, 2002)

A woman who was insured by State Farm was injured in an automobile accident.
Her doctor recommended that she have an MRI. Somehow (not revealed in the court’s
opinion) Medical Management Group of Orlando (MMGO) learned of the doctor’s
recommendation and referred the woman to Premier Advanced Imaging Network (Premier).
Premier performed the MRI and billed MMGO $350. MMGO then billed State Farm
$1,400. State Farm refused to pay. MMGO sued under a state statute that requires
insurers to pay 80% of "medically necessary medical…services." MMGO
asserted that it was entitled to bill State Farm for the MRI pursuant to an
agreement whereby it "leased" space, equipment, and services from
Premier and then accepted assignment of Premier’s rights to bill a commercially
reasonable fee for its services.

The District Court of Appeal of Florida agreed with the trial court that the
arrangement "is nothing more than a fee-splitting scheme to compensate
for MRI referrals," which is prohibited by state law. Moreover, the court
found that the provision of referral and billing services does not constitute
a medically necessary medical service, and thus was not compensable as such.