Thyssenkrupp Elevator Corp. v. Lasky

In Thyssenkrupp Elevator Corp. v. Lasky, 868 So. 2d 547 (Fla. 4th DCA 2003), the plaintiff's medical providers had reduced the amounts of the plaintiff's medical bills as required by the providers' participation in the Medicare program. The Fourth District held that the defendant was entitled to have the plaintiff's award for medical expenses reduced by the amount of the Medicare write-offs, reasoning that "a plaintiff has suffered no damage from the higher charge by the provider when it later accepts Medicare payment in full satisfaction of the charge." 868 So. 2d at 551. The district court noted that when a provider accepts a contractual fee in full satisfaction of a bill, "the original charge becomes irrelevant because it does not tend to prove that the claimant suffered any loss by reason of the charge." Id.