Personal Injury Damages Are Not Limited by Amount Medical Insurance Pays

There has been an on-going controversy aboutdifferential was the difference between the full
whether insured victims may recover the fullamount of the medical providers' bills
amount billed by healthcare providers for medical($189,978.63) and the lesser amount paid by the
expenses in a personal injury lawsuit or theprivate healthcare insurer in cash payments to the
reduced amount that insurers negotiate withmedical providers that the providers had agreed
healthcare providers. The defense bar has reliedto accept as payment in full pursuant to their
on cases that have induced courts to reduceagreements with the insurer ($59,691.73). The
medical expense awards in personal injury lawsuitsCourt of Appeals declared that the plaintiff was
to the amount actually paid by the privateentitled to the full amount of the medical
healthcare insurance carrier for the personal injuryexpenses award, $189,978.63.
victim. The plaintiff's bar has argued that the fullThe plaintiff contested the motion of the
amount is recoverable under the Collateral Sourcedefendant by contending that she was not a
Rule, because a responsible victim who has hadMed-Cal beneficiary, and that she was suing a
insurance coverage in place should not be subjectprivate defendant. Therefore, the plaintiff
to a reduced award because his or her insurancecontended that she should be permitted under the
company has negotiated a lesser price for theCollateral Source Rule and the applicable measure
medical services provided.of damages to recover the full amount of the
In a recent case out of San Diego County, thereasonable "cost" or "value" of the past medical
California Court of Appeals supported theexpenses paid or incurred as a result of her
Collateral Source Rule analysis and declared thatinjuries and not just what her private healthcare
victims of personal injuries may recover the fullinsurer paid to her medical providers. The plaintiff
amount of medical bills billed to them byalso argued that under the Collateral Source Rule,
healthcare providers, even though their privatethe Court should exclude evidence of the benefits
healthcare insurance carrier paid less under athat the plaintiff's healthcare provider paid.
negotiated contract with the provider.The plaintiff asserted that she received two
The Court of Appeals decided whether a plaintiffcollateral source benefits from her healthcare
who has private healthcare insurance in a personalinsurer: (1) a reduced alternative rate for cash
injury case may recover, under the Collateralpayments, and (2) a negotiated rate differential.
Source Rule, economic damages for the amountThe plaintiff said her insurance generated benefits
of past medical expenses that the plaintiff'sthat included non-cash benefits and services such
healthcare providers have billed out, but whichas preferred provider listings that are
neither the plaintiff nor the plaintiff's healthcareendorsements of medical providers, a guaranteed
insurer is obligated to pay because the providersflow of patients who are members of the
have agreed, under contracts into which theyinsurer's healthcare plan and timely payments
entered with the insurer to accept (as payment infrom pooled premiums that reduces the number
full) payment in an amount that is less than theof collection actions the providers must bring to
amount the providers billed out. As the Court said,collect payments from their patients. The Court
"Stated differently, is the difference (theof Appeals referred to those two items as "two
negotiated rate differential) between (1) the fullcollateral source benefits" of plaintiff's healthcare
amount of the medical provider's bills, and (2) theinsurance.
lesser amount paid by the private healthcareThe Court said that under the Collateral Source
insurer in cash payments to the medical providersRule, the benefits of the private healthcare
that the providers have agreed to accept asinsurance of the plaintiff were a collateral source
payment in full pursuant to their agreements withbenefit because it was conferred upon the plaintiff
the insurer, a benefit within the meaning of theas a direct result of her own thrift and foresight
Collateral Source Rule such that the plaintiff isin procuring private healthcare insurance. The
entitled under that rule to recover the amount ofCourt declared that under California's Collateral
the negotiated rate differential as part of herSource Rule, a person who has invested in
economic damages award?"insurance premiums to ensure her medical care
Before the trial Court entered judgment, theshould receive the benefits of her thrift and the
defendant filed a motion seeking an orderdefendant, as a party liable for a plaintiff's injuries,
reducing the jury's special verdict for the plaintiff'sshould not garner benefits from an insured
past medical expenses by $130,286.90 (theplaintiff's providence.
negotiated rate differential). That negotiated rate