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Florida appeals court reverses PIP reimbursement ruling for State Farm
The Third District Court of Appeal reversed a county judgment that awarded Universal X Rays $8.24 and remanded for entry of judgment for State Farm, plus fees and costs.
An $8.24 personal injury protection, or PIP, reimbursement dispute in Florida has ended in a reversal for State Farm Mutual Automobile Insurance Company after the state’s Third District Court of Appeal overturned a county court judgment.
Insurance Business reports that the case began in 2022 when Universal X Rays Corp. brought suit after taking an assignment of benefits from a State Farm insured injured in a car accident. State Farm had already paid Universal for diagnostic tests, but the parties disagreed on the reimbursement amount under Florida’s no-fault statute and the insured’s auto policy, which ties payments to the schedule of maximum charges.
The disagreement centered on whether State Farm properly used Medicare’s Budget Neutrality Adjustment, or BNA, in its calculation. The county court sided with Universal, but on appeal Universal reversed its position and confessed error on the BNA issue, and the appeals court agreed.
The court reversed the judgment, allowed State Farm to withdraw a separate argument about which Medicare source applies, and remanded with directions to enter judgment for State Farm and award fees and costs. A wider “Limiting Charge” conflict among Florida appellate courts remains unresolved, and industry groups including the Personal Insurance Federation of Florida and the National Association of Mutual Insurance Companies filed as amici, according to Insurance Business.