An $8.24 payout dispute reached a Florida appeals court - and it ended with a reversal for State Farm.
On July 15, 2026, the Third District Court of Appeal reversed a county court judgment that had gone against State Farm Mutual Automobile Insurance Company (State Farm) in a personal injury protection (PIP) case. The decision is not yet final and is subject to any timely motion for rehearing.
The dispute began in 2022, when Universal X Rays Corp. (Universal) sued in county court. Universal had taken an assignment of benefits from a State Farm insured injured in a car accident, and it sought PIP benefits under Florida's no-fault statute and the insured's auto policy. State Farm had already paid Universal for diagnostic tests. The disagreement was over the amount.
State Farm's policy limits PIP reimbursement to the statute's "schedule of maximum charges." In its calculation, State Farm applied a factor built into that schedule's formula - Medicare's Budget Neutrality Adjustment, or BNA. Universal said it should not have.
The county court sided with Universal, denied State Farm's motion, granted Universal's, and entered judgment for Universal for $8.24. State Farm appealed.
State Farm raised two issues on appeal. The first, the "Limiting Charge" issue, concerns which Medicare source applies when calculating provider charges in PIP suits - a question already the subject of a certified conflict among Florida's appellate courts. The second was whether State Farm properly included the BNA, which was the basis of the trial court's ruling.
After reviewing the record and State Farm's brief, Universal reversed position. It concluded that State Farm was right on the BNA and confessed error. The appeals court agreed.
By agreement of the parties, the court accepted the confession on the BNA, let State Farm withdraw its Limiting Charge argument, reversed the judgment, and remanded with directions to enter judgment for State Farm and award fees and costs.
For claims professionals, the takeaway is narrow. The ruling addressed the BNA, not the broader Limiting Charge conflict, which State Farm withdrew and which remains unresolved across Florida's courts. Two industry groups - the Personal Insurance Federation of Florida and the National Association of Mutual Insurance Companies - had filed as amici, a sign of how closely insurers are following these PIP reimbursement disputes.
