In determining the reasonable value of medical services a doctor provided to patients covered by a medical plan with which the doctor had no contract setting fees, the trial court properly considered evidence of what other doctors charged and the Medicare reimbursement rate for the services rendered. In determining the reasonable value of medical services provided by a doctor (or a medical group) to patients covered by a medical plan with which the treating doctor has no contract setting fees, the trial court may properly consider not only (a) the fees the treating doctor usually charges for the same services and (b) the fees the treating doctor is normally paid for those services (the issue decided in Children’s Hospital Central California v. Blue Cross of California (2014) 226 Cal.App.4th 1260) but also (c) the amount charged by other doctors for the same services, and (d) the amount paid by Medicare for those services. Here, the trial court properly considered all four of these types of evidence and reached a conclusion as to the reasonable value of the doctor’s services that was supported by substantial evidence.
California Court of Appeal, Second District, Division 1 (Lui, J.); May 23, 2017; 2017 WL 2242981