Tuesday, May 5, 2009
No Penalty against hospital for collection efforts
St. Francis Medical Center provided treatment including back surgery to claimant allegedly injured from a 1996 work injury. Claimant sued the hospital after collection efforts by the hospital, under the penalty provisions of 287.140.13. The court found the collection efforts did not violate provisions of 287.140.3, subjecting the hospital to penalties, as claimant initially told the hospital to bill her group insurance and later told her to send the bills to her employer. The court noted that even though claimant obtained a temporary award and sought reimbursement did not avoid summary judgment as claimant induced the hospital to bill her group. The case is Beard v St. Francis Medical Center, SD 29126 (Mo. App. 5-4-09).