Patchett v. Lee

60 N.E.3d 1025 (2016)

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Nature of the Case

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Facts

Patchett (D) admits she drove her car negligently in striking Lee's (P) vehicle and causing Lee injuries that required medical treatment. D admitted she was liable for the accident. D contests the reasonable value of D's medical care, so the parties prepared for a trial on damages. The parties disagree whether D could introduce evidence that P's providers accepted a reduced amount as payment in full. Specifically, because D was enrolled in the Healthy Indiana Plan (HIP), a government-sponsored health care program, her providers, as HIP participants, accepted HIP's prevailing reimbursement rates of $12,051.48 in full satisfaction of those charges-an 86-percent discount from the amounts billed. P moved before trial to prevent the jury from hearing the reduced HIP rates. The trial court granted P's motion. It found that the HIP payments are subject to the collateral-source statute and the court excluded the HIP amounts under Evidence Rule 403 because it found HIP's reduced rates would only confuse the jury.