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Centura Health Corp. v. French.

2020 COA 85. No. 19CA0023. Election Law—Campaign Finance Violation—Colorado Administrative Procedure Act—Appeals.

May 28, 2020

French was admitted to Centura Health Corporation and Catholic Health Initiatives Colorado, d/b/a St. Anthony North Health Campus (the Hospital) for elective spinal fusion surgery. The Hospital considered French an out-of-network patient. Before the surgery, French received a cost estimate stating the surgery would cost $57,601.77 and that after her insurance payment she would be responsible for $1,336.90. French also signed a hospital services agreement (HSA) three separate times before surgery. The HSA stated that reimbursement or payment from an insurance company is not guaranteed, and French would pay any Hospital charges not otherwise paid by insurance.

French’s surgery had complications and she was billed $303,709.48. French paid $1,000 and her insurance paid $73,597.35, leaving a balance of $229,112.13. After several failed attempts to collect the balance from French, the Hospital sued her for breach of contract to recover the unpaid bill. The trial court denied the Hospital’s motion for a declaratory judgment asking the court to hold that the HSA’s price term “all charges” unambiguously referred to the Hospital’s chargemaster rates, which is a computer billing system with predetermined rates for specified medical services. A jury found French breached the HSA by failing to pay. Because the trial court had previously held that the term “all charges” was ambiguous, the jury was asked to interpret the term. The jury concluded “all charges” meant the “reasonable value of the goods and services” provided, and it found that French owed the Hospital $766.74.

On appeal, the Hospital argued that the trial court erred by ruling that the term “all charges” in the HSA was ambiguous, thereby allowing the jury to interpret the term and impose a reasonableness requirement. The Court of Appeals analyzed relevant decisions from other jurisdictions and concluded that the HSA’s price term “all charges” unambiguously referred to the Hospital’s chargemaster rates and was sufficiently definite to be enforceable. Accordingly, the trial court erred.

The judgment was reversed and the case was remanded with directions.

Official Colorado Court of Appeals proceedings can be found at the Colorado Court of Appeals website.

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