The Georgia Supreme Court on Monday reversed a Court of Appeals decision when it ruled The Medical Center (now Midtown Medical Center) must provide detailed records from the hospital to a woman suing to determine whether its charges for her care were unreasonable.
Danielle Bowden was involved in a 2011 vehicle collision in Columbus and was taken by ambulance to The Medical Center, where she received emergency treatment and was hospitalized for three days, resulting in a $21,409.59 bill since she was uninsured.
The treatment included emergency surgery, two CT scans and physical therapy.
While Bowden was hospitalized, her mother signed a document entitled "Patient Acknowledgment, Assignment of Benefits and Consent Agreement," which said she agreed for her daughter that she was "individually obligated to pay the account in full of the hospital, and attending physicians. "
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After Bowden presented her medical bills to Enterprise, which had insured the rental car up to $25,000, the hospital filed a lien to recover the costs of Bowden's care, also offering to settle the bill for $8,333.
Bowden refused and could not reach an agreement with the hospital, alleging the hospital's charges were unreasonable and excessive because she was charged more than an insured patient. She said the hospital would be unjustly enriched if it collected the full amount due to deceptive trade practices.
To support her claim, Bowden sought during the discovery process the hospital's pricing agreements with various insurance companies, the number of uninsured patients it treated and information about the hospital's revenue. Her lawyer also requested, among other documents, itemized bills of what she would have been charged if covered by a number of different programs.
The hospital argued the information was irrelevant and involved confidential and proprietary information. The requests were "overly broad and burdensome," according to the hospital.
The trial court granted Bowden's motion, but the state Court of Appeals reversed the ruling, saying the hospital already had provided Bowden with information required under state law.
But that ruling was overturned by the Georgia Supreme Court ruling Monday that stated, "Where the subject matter of a lawsuit includes the validity and amount of a hospital lien for the reasonable charges for a patient’s care, how much the hospital charged other patients, insured or uninsured, for the same type of care during the same time period is relevant for discovery purposes," the opinion said.
As to whether Bowden's request was "relevant," the court said "in the broad discovery rather than the narrower trial sense of that term — to the reasonableness of The Medical Center’s charges for her care. The fair and reasonable value of goods and services is often determined by considering what similar buyers and sellers have paid and received for the same product in the same market, with adjustments upward or downward made to account for pertinent differences, and we see no reason why the same cannot be true of health care.”
Bowden is represented by Charles and Austin Gower. Bobby Scott is representing the hospital.