877 N.W.2d 124
Iowa2016Background
- Plaintiffs (Young, Haigh, Runyon) sued HealthPort alleging fees charged to produce medical records and billing statements exceeded limits in Iowa Code §622.10(6).
- HealthPort is a vendor contracted by healthcare providers to fulfill records requests; plaintiffs allege HealthPort required payment of excess per-page, basic, and electronic delivery fees before releasing records.
- HealthPort moved to dismiss for failure to state a claim, arguing the statute governs only "providers" and does not limit fees charged by non-provider vendors.
- The district court denied the motion to dismiss; HealthPort sought interlocutory appeal, which the Iowa Supreme Court granted.
- The petition pleads facts (treated as true on a motion to dismiss) that HealthPort acted as an agent of providers when fulfilling requests, and thus may be bound by the statute’s fee limits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Iowa Code §622.10(6) limits fees charged by a non-provider vendor fulfilling records requests for a provider | The statute limits fees for any entity that produces records under a provider’s request; HealthPort must comply when acting on providers’ behalf | The statute applies only to entities that meet the statutory definition of "provider," so HealthPort (a vendor) is not regulated | The court affirmed denial of dismissal: on pleaded facts HealthPort acted as provider agents, and agents cannot charge more than providers may legally charge under §622.10(6) |
Key Cases Cited
- Cotton v. Med-Cor Health Information Solutions, Inc., 472 S.E.2d 92 (Ga. Ct. App. 1996) (entities fulfilling provider records requests cannot charge fees greater than statute permits for providers)
- Pratt v. Smart Corp., 968 S.W.2d 868 (Tenn. Ct. App. 1997) (vendor acting as hospital’s agent cannot do what hospital is forbidden to do by statute)
- C & J Vantage Leasing Co. v. Wolfe, 795 N.W.2d 65 (Iowa 2011) (agency principles: actual and apparent authority)
- Cutler v. Klass, Whicher & Mishne, 473 N.W.2d 178 (Iowa 1991) (courts should avoid premature dismissals; many factual disputes better resolved post-pleading)