New Ruling on Submission for Medical Expenses in No-Fault Claims

Cally Kjellberg Nelson

A recent decision by the Minnesota Court of Appeals impacts the submissions of medical expenses in no-fault claims. The Court held that Minnesota law bars a no-fault claim where the medical provider fails to submit the medical expenses to the no-fault insurer within 6 months from the date of service or the date the health care provider knew or was informed of the correct name and address of the no-fault insurer. 

It came in a decision in the case of Western National Insurance Company v. Nguyen and pertains to Minn. Stat. § 62Q.75, subd. 3.

Here are three key takeaways:

  • Minn. Stat. § 62Q.75, subd. 3 applied, because the medical provider had submitted only one bill to the insurance company within the statutory six-month time frame, so the medical provider could not collect its remaining charges.
  • The patient did not suffer a loss that would entitle him to no-fault benefits, other than the one expense initially submitted to Western National for payment.
  • Medical-expense benefits never became due because the medical providers did not submit its claim to the insurance company pursuant to uniform electronic transaction standards.

Here are the details:

In January 2013, Jon Nguyen's no fault claim was denied in its entirety at arbitration. Following the arbitration, Nguyen began treating at a new provider, the Center for Diagnostic Imaging (CDI). When CDI submitted the first bill to Western National for payment, it was denied based on a previous Independent Medical Examination and the January 2013 arbitration.

Nguyen continued treating with CDI, but CDI stopped submitting bills to Western National. Nguyen filed for another no-fault arbitration in April 2016, seeking payment for his CDI bills which now exceeded $10,000.

Western National asserted Minn. Stat. § 62Q.75, subd. 3 as a defense to the claim. After the arbitrator awarded Nguyen his claims, Western National appealed.

 

The district court concluded that Minn. Stat. § 62Q.75, subd. 3 applied, because CDI had submitted only one bill to Western National within the statutory six-month time frame, so CDI could not collect its remaining charges.

The district court concluded Nguyen did not suffer a loss that would entitle him to no-fault benefits, other than the one expense initially submitted to Western National for payment.

The district court also concluded that medical-expense benefits never became due pursuant to Minn. Stat. § 65B.54, subd. 1, because CDI did not submit its claim to Western National pursuant to uniform electronic transaction standards. Nguyen appealed and the Minnesota Court of Appeals affirmed the district court's decision.
The Minnesota Court of Appeals noted that although Minn. Stat. § 62Q "expressly sets forth only requirements for a health-care provider and not an insured, a health-care provider's failure to meet these requirements does affect whether the insured experiences a loss." The Court also agreed with the district court's holding that CDI did not comply with the electronic-transaction standards required by Minn. Stat. § 65B.54, subd. 1.

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