Checks and Balances: Court of Appeals Holds the No-Fault Act’s One Year Back Rule Applies to Balance Bills

The Court’s opinion in Casanova is published and therefore is binding authority on all courts addressing this issue. Casanova affirms in the wake of Covenant that any claims the provider may have had against a patient-insured for the payment of services rendered for reasonable and necessary medical care and treatment of injuries sustained in a motor vehicle accident and covered by a no-fault policy are not implied contracts, but claims under the No-Fault Act. Further, while Covenant requires that a medical provider address the reasonableness of charges paid with its patient-insured and not the insurer, the One-Year-Back Rule applies to “balance bill” situations.

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