Wayne M. Chiurazzi Law, Inc., et al. v. MRO Corporation

The issue this case presented to the Pennsylvania Supreme Court centered on the interpretation of Sections 6152(a)(1) and (a)(2)(i) of the Medical Records Act ("MRA,"42 Pa.C.S. secs. 6151-6160), which requires businesses such as appellee MRO Corporation, which reproduces medical records for patients and their representatives, to limit their copying charges to their estimated actual and reasonable expenses of reproducing requested charts or records (subject to a statutory ceiling rate), or whether such businesses may simply charge the statutory ceiling rate. Appellant asked the Court to review the Superior Court's finding that, where a medical records reproducer fails to disclose and charge its estimated actual and reasonable expenses and instead charges the MRA's ceiling rates which the records requestor then pays, the defenses of "voluntary payment" and "prior approval" bars the records requestor from maintaining a breach of contract claim to recoup alleged overpayments. MRO did not dispute that the MRA requires the records reproducer to disclose to the requestor “the estimated actual and reasonable expenses” of reproduction. But, MRO argues that the "expenses" so disclosed do not represent actual costs of reproduction; rather, MRO argues that "expenses" refers to the cost to the party making the request, and that expense is determined by the pricing schedule. In MRO's view, the pricing schedule establishes the "expense" to be estimated and then passed on to the requestor. "MRO's construction of the Act is intricate and ingenious in some respects, and it articulates what may be a rational and legitimate approach to the general question of how best and fairly to regulate the expenses of securing medical records." However, the Supreme Court did not believe that the structure and plain language of the provisions of the Act at issue here supported MRO's construction. The Supreme Court reversed the Superior Court and remanded the matter to the trial court for further proceedings. View "Wayne M. Chiurazzi Law, Inc., et al. v. MRO Corporation" on Justia Law