Supreme Court of Delaware
State Farm v. Spine Care Delaware
September 9, 2020
Summary
The Supreme Court of Delaware reversed the Superior Court's declaratory judgment ruling concerning State Farm's use of Medicare-based multiple payment reductions for bilateral and multilevel spinal injections. It held that Spine Care Delaware, as the plaintiff seeking declaratory relief, bore the burden to prove that its charges were reasonable and that State Farm was not entitled to apply the reductions. The Court remanded for reconsideration of the reasonableness of Spine Care's charges using a flexible approach, with comparable charges by similarly situated providers treated as particularly relevant.