California appeals court rules against hospital billing Progressive directly from UM policy

The dispute arose after a patient, M.G., who was covered by Medi-Cal, received emergency and ongoing treatment from Dameron following an automobile accident. During the admissions process, either M.G. or her representative signed the hospital’s Conditions of Admission (COA) form. That form included an AOB clause covering “all uninsured and underinsured motorist insurance benefits payable to or on behalf of the patient.” Dameron did not bill Medi-Cal. Instead, the hospital billed Progressive for $2,686.75 directly from M.G.’s UM coverage.

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