Thompson v. Burley Inn, Inc.
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The Supreme Court of the State of Idaho upheld a decision by the Idaho Industrial Commission that required an employer and its insurance company to pay the full amount of a medical invoice for an employee's workers' compensation claim, even though the employee's medical expenses were fully covered by Medicaid. The employee, Nickole Thompson, worked at Burley Inn, whose workers' compensation insurer was Milford Casualty Insurance Company. After Thompson suffered a work-related injury, Burley Inn and Milford denied her workers' compensation claim for a hip replacement surgery. Thompson underwent the surgery anyway, with Medicaid covering the cost.
Thompson later filed a claim with the Industrial Commission, which found the hip replacement surgery was connected to her work injury and awarded her medical benefits based on the full invoice amount for the surgery. Burley Inn and Milford appealed the decision, arguing that the "full invoice" rule should not apply when Medicaid has already covered the medical expenses.
The state Supreme Court, however, upheld the Commission's decision, asserting that excluding Medicaid recipients from the full invoice rule could encourage employers to deny workers' compensation claims of workers they suspect of being Medicaid recipients. The court also noted that the full invoice rule was consistent with Idaho's workers' compensation law and was intended to prevent employers from denying legitimate claims. The Court also concluded that the employer and insurer had standing to bring the appeal and that Thompson was not entitled to attorney fees on appeal.
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