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A Better Partnership
May 27, 2009

COA Opinion: Marquette General Hospital, Inc. v. County of Baraga

In its published opinion in Marquette General Hosptial, Inc. v. County of Baraga, the Court of Appeals reversed the trial court's award of summary disposition (with prejudice) to the County of Baraga in Marquette General Hospital's suit to collect a medical bill related to the in-patient hospital care of an inmate at the Baraga County Jail. The court found that the Hospital complied with MCL ' 801.4, by making a reasonable effort to determine if there was another source for payment (such as health insurance or Medicaid), before submitting an invoice to the County. But, the court found that the statute required the Hospital to include a written statement of its efforts to secure an alternative source of funding along with its invoice to the County. The court affirmed the trial court's conclusion that the Hospital's verbal statements failed to meet this statutory requirement, but disagreed that the proper remedy was dismissal of the Hosptial's claim with prejudice. Instead, the court stated that the Hospital could comply with the statute by resubmitting the invoice along with a proper written statement.

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