Is Police and Fire Medical Association Considered a ''Health Care Insurer'' ?
In Holgate v. Workmen's Compensation Appeal Board (City of Philadelphia), 104 Pa. Commw. 32, 521 A.2d 82 (Pa. Cmwlth. 1987) the Court held that the record was not sufficiently developed to determine whether the Police and Fire Medical Association, which had paid a medical bill related to a work-related condition, was a health care insurer providing health insurance to firemen who elected its coverage as it claimed or was simply an adjunct of the union as the referee found.
The Court remanded for an evidentiary hearing to determine whether it qualified as an insurer.