Roy v. Farmers & Merchants Insurance

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David Newbern, Justice.

In this case we interpret, for the first time, a provision in Ark. Code Ann. § 23-89-208 (1987) requiring “reasonable proof of all benefits” be made to an insurance company. The issue stems from a further provision of the Statute that the insurer is liable for sanctions if a claim is not paid within 30 days after receipt of “reasonable proof as to all benefits accrured.” We hold that sending a hospital bill, unaccompanied by any sort of signed application proving that the medical expense entitles the sender to an insurance policy “benefit” is not sufficient to satisfy…