April 29, 2024 | Legal Alerts
On April 25, 2024, the Florida Supreme Court issued its decision in Allstate Insurance Company, et. al, v. Revival Chiropractic, LLC, SC2022-0735. More than a year after oral argument, the Court finally and definitively ruled on “Billed Amount” concluding “…the provisions of both the statute and the policy support Allstate’s payment of 80% of the amount of the charges submitted.” Id. Although Revival made its way to the Florida Supreme Court by way of certified question posed by the United States Court of Appeal for the Eleventh Circuit, the Billed Amount issue has pervaded Florida state courts and PIP suits for well over half a decade. As expressed by the Court, “the question for decision is whether the insurer here may pay 80% of a charge submitted by a provider even when that reimbursement amount is less than the amount that would be reimbursable under the limitations of the statutory schedule of maximum charges.” In no uncertain terms, the Court found the Allstate policy expressly authorized such a payment and nothing in the PIP statute prevented payment in accordance with Allstate’s policy.
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