IV Solutions, Inc. v. PacifiCare Life & Health Insurance Co.
JusticiabilityDoctri
When does the statute of limitations begin running for a health care provider's claims against an insurance company?
QUESTION PRESENTED When a health care insurance company issues an Explanation of Benefits (““EOB”) expressly inviting a health care provider to “notify it of additional information clarifying the services and/or charges,” and thereafter engages in an extended dialogue with the health care provider regarding the reprocessing of the provider’s claims in light of such additional information, does the statute of limitations begin running as a matter of law immediately upon the issuance of that Explanation of Benefits, even though the insurance company, through its representatives, thereafter communicated to the provider on numerous occasions that the provider’s claims were still being reviewed and reprocessed?