Allstate Insurance Company v. Revival Chiropractic, LLC

Summary

The court answered the rephrased certified question affirmatively, holding that an insurer may pay 80% of a provider's submitted charge even when that charge is less than 80% of the amount available under the statutory schedule of maximum charges. The PIP statute establishes an overarching requirement to pay 80% of reasonable expenses, while the schedule operates as an optional ceiling rather than an exclusive reimbursement method. The policy expressly authorized payment of 80% of the submitted charge, and no statutory provision invalidated that term.