A Florida circuit court has ruled that State Farm cannot refuse to process and pay a medical provider’s personal injury protection (PIP) claims simply because the provider uses a Letter of Protection (LOP) to defer patient cost-sharing. The court rejected the insurer’s argument that a billing practice used across the PIP industry for more than two decades constitutes fraud.

In an order issued on February 4, 2026, Thirteenth Judicial Circuit Judge Paul L. Huey granted partial summary judgment in favor of Complete Care Centers, LLC against State Farm Mutual Automobile Insurance Company in Hillsborough County, Florida.

What Happened

In Florida, PIP insurance covers medical expenses for patients injured in motor vehicle accidents. An LOP allows the treating provider to defer collecting patient deductibles and coinsurance until the patient’s bodily injury claim resolves through settlement or verdict. This practice has been standard in Florida’s PIP industry for decades.

State Farm took the position that Complete Care’s use of LOPs constituted insurance fraud under Florida law, and that the provider was required to collect up to $3,500 in patient cost-sharing obligations before submitting any PIP claim. Based on this interpretation, State Farm stopped processing all of Complete Care’s PIP claims in April 2025.

Judge Huey disagreed. The court found that Florida’s anti-fraud statute has expressly permitted LOPs since 2003, and that nothing in the law has changed since. State Farm admitted that until a provider’s charges are actually submitted to the insurer, it is “impossible” to know what deductible or coinsurance amount applies. The court pointed out that State Farm’s own PIP policies list the copayment amount as “$0.00.” Requiring a provider to collect unknown amounts before submitting a claim, the court reasoned, was a requirement the provider could not satisfy.

The court characterized State Farm’s blanket refusal to pay as a self-imposed injunction that harmed both Complete Care and State Farm’s own insureds. The judge noted that LOPs have been standard practice throughout his 25 years on the bench, and that the parties have been litigating this issue for approximately 10 years. State Farm did not present any material factual support for its position. The court did note that the ruling does not eliminate a provider’s duty to make a good faith attempt to collect deductibles and coinsurance; it permits deferral under an LOP, not a permanent waiver.

Why This Matters for Medical Providers

This case involves Florida PIP law, but the insurer’s approach will look familiar to any medical provider dealing with reimbursement disputes. State Farm adopted an aggressive interpretation of an existing statute and used it to justify a blanket refusal to pay legitimate claims. Complete Care has had to litigate for approximately 10 years over this dispute.

The same dynamic plays out in other areas of insurance reimbursement. Under the Federal No Surprises Act, insurers routinely set artificially low payment amounts and delay or refuse to pay arbitration awards. In workers’ compensation, carriers underpay or deny claims and count on providers not having the resources to fight back. In each of these contexts, providers who do not challenge insurer denials and underpayments forfeit money they are legally owed.

For providers dealing with PIP disputes in particular, this ruling confirms that insurers cannot use the anti-fraud statute to block payment on claims involving LOPs. But as the Complete Care case shows, getting an insurer to follow the law often requires legal action. Providers who are having PIP claims denied or delayed should not wait to find out how much revenue they are losing.

An insurer’s denial is not the final word. Legal remedies are available, and providers should be evaluating whether they have claims worth pursuing.

The case is Complete Care Centers LLC v. State Farm Mutual Automobile Insurance Co. et al., Case No. 25-CA-001063, in the Thirteenth Judicial Circuit Court of Florida, Hillsborough County.

PIP reimbursement disputes are governed by state law and require attorneys licensed in the relevant state. But providers dealing with PIP underpayments are often facing the same problem on their commercial insurance claims. Out-of-network providers who treat auto accident patients frequently also have claims eligible for Federal No Surprises Act arbitration, where insurers are paying a fraction of billed charges and providers have a legal right to challenge those payments.

Minevich Law Group, P.C. represents healthcare providers nationwide in Federal No Surprises Act arbitration and in New York and New Jersey for state surprise billing arbitration, PIP disputes, workers’ compensation collection, health law, and civil litigation.

Call 516-202-2196 or schedule a free consultation.