SHANDS TEACHING HOSPITAL & CLINICS OF THE UNIVERSITY OF FLORIDA, FOR AND ON BEHALF OF THE BOARD OF REGENTS OF THE STATE OF FLORIDA, APPELLANTS,
v.
COUNCIL OF THE CITY OF JACKSONVILLE, APPELLEE
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Shands Teaching Hospital sought reimbursement from Jacksonville for emergency treatment of an indigent city resident with a brain tumor. The court reversed a hearing officer's decision denying payment, holding that the statute's emergency exception applied and Jacksonville must pay for the life-saving treatment rendered at a regional referral hospital.
The city must pay for emergency medical treatment provided at a regional referral hospital when: the patient is an indigent resident of the county being billed; the attending physician determines the condition to be an emergency; the treatment is rendered at a regional referral hospital; and the condition would deteriorate from failure to provide such treatment.
[1] A county is not required to pay for hospital services provided to an indigent resident at a regional referral hospital if such services are available at a local hospital…
[2] An exception to the rule requiring local treatment for indigent residents exists when the patient receives emergency medical treatment for a condition that would deterior…
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The statute makes an exception to this rule where the patient is treated for any emergency medical condition which will deteriorate from failure to provide such treatment when the attending physician determines the condition to be of an emergency nature.”
Establishes the statutory emergency exception to the general rule that counties need not pay for regional referral hospital services available locally.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceLinda Sue Austin, an indigent resident of Jacksonville, was hospitalized at Shands Teaching Hospital with a brain tumor requiring immediate emergency …
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LILES, WOODIE A. (Retired), Associate Judge.
Linda Sue Austin was hospitalized at Shands Teaching Hospital with a diagnosis of a brain tumor in danger of causing herniation. She was a resident of the City of Jacksonville and had previously been treated on an outpatient basis at Shands. On the particular day she was hospitalized, the attending physician determined her condition required immediate emergency hospitalization. Because she was an indigent, Shands, pursuant to Section 154.306, Florida Statutes, submitted the hospital bill for her treatment to the City of Jacksonville. The City refused to pay the bill and the matter was referred to a hearing officer, who conducted a hearing pursuant to Section 154.-312, Florida Statutes. The hearing officer held that Jacksonville was not required to pay the bill for the reason that Austin, even though an indigent resident of Jacksonville, should have been treated in Jacksonville because its hospital was also a regional referral hospital under the statute, and the rule required that “no county shall be required to pay for services at a regional referral hospital when such services are available in a local hospital in the county where the indigent resides.” The statute makes an exception to this rule where the patient is treated for any emergency medical condition which will deteriorate from failure to provide such treatment when the attending physician determines the condition to be of an emergency nature. The effect of the hearing officer’s order was that Austin should have returned to Jacksonville for treatment since there was a regional referral hospital in Jacksonville.
We disagree with the hearing officer’s recommended order and with the City of Jacksonville’s formal adoption of the order. The attending physician found that Austin was suffering from a brain tumor and needed immediate treatment then and there. Since Shands Teaching Hospital was also a regional referral hospital, and since Austin was a resident of the State of Florida and of the county being requested to pay, and she was a certified indigent by the county wherein she resided, and since the emergency medical treatment was diagnosed and was rendered in a regional referral hospital, even though not in the county in which she resides, and the condition would deteriorate from failure to provide such treatment, the criteria of the statute was met and the City of Jacksonville should pay Shands Teaching Hospital the total sum of the medical bill.
REVERSED AND REMANDED with directions for proceedings consistent with this opinion.
SHIVERS and WENTWORTH, JJ., concur.
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Dade Cnty. v. Am. Hosp. OF Miami, Inc., 463 So. 2d 232 (Fla. 3d DCA 1984)…re rendered in another county. See, St. Mary’s Hospital v. Okeechobee County Board of County Commissioners, 442 So. 2d 1044 (Fla. 4th DCA 1983);1 Shands Teaching Hospital & Clinics of University of Florida v. Council of City of Jackson [*235] ville, 398 So. 2d 907 (Fla. 1st DCA 1981); Tallahassee Memorial Regional Medical Center v. Lewis, 399 So. 2d 106 (Fla. 1st DCA 1981). The quotation at p. 233 thus expresses the legislative policy only that, in that situation, the county where the indigent lives should be…