Patchett v. Lee – October 22, 2016

In Stanley v. Walker, 906 N.E.2d 852 (Ind. 2009), the Indiana Supreme Court interpreted Indiana’s collateral-source statue to permit a defendant to introduce evidence of discounted reimbursements negotiated between plaintiff’s medical providers and plaintiff’s private health insurer so long as insurance was not referenced.

On October 21, the Indiana Supreme Court ruled the same rationale applied to reimbursements by government payers. See Patchett v. Lee, 60 N.E. 3d 1025 (Ind. 2016). More specifically, the Indiana Supreme Court held in Patchett that reduced payments accepted as payment in full are a probative, relevant measure of the reasonable value of a plaintiff’s medical care and admissible, regardless of whether they are negotiated (private insurers) or mandated (government payers). Importantly, the Indiana Supreme Court made clear that the parties should expect and the Courts should presume the admissibility of both the amount charged and the discounted amount accepted as payment in full.