In Weston v. AKHappytime, LLC,[1] the Alaskan Supreme court held undiscounted medical bills are admissible at trial. Weston slipped and fell on ice in the parking lot of a hotel owned by AKHappytime, fracturing her right wrist and leg in the process. Her hospital bills totaled up to over $135,000, but Medicare settled the bills in full by paying $24,247.45. At trial, AKHappytime moved to exclude the original medical bills arguing they were inflated and did not represent the reasonable value of medical services rendered. The Superior Court granted the motion and held that Weston could only recover the adjusted rates accepted by her provider. On appeal, the Supreme Court considered two primary questions; first, whether it was an error to exclude evidence of the undiscounted medical bills, and second, whether the difference between the bills and what Medicare paid be viewed as a benefit to Weston from a collateral source. For the first question, the Supreme Court held that an injured party is allowed to introduce the full, undiscounted medical bills at trial. Since both the amounts actually paid and the amount written off are relevant in determining the reasonable value of the medical services, the complete medical bills are necessary evidence. For the second question, the Court held the negotiated rate differential would fall under the collateral source rule, and consequently, is subject to the post-verdict procedures of AS09.17.070.
[1] 445 P.3d 1015 (Alaska 2019).