Bergstein v. Palm Beach County School Board

In this workers’ compensation case, Claimant appeals an order of the Judge of Compensation Claims (JCC) finding the parties’ disagreement regarding payment of outstanding bills for medical care to be a reimbursement dispute over which she has no jurisdiction, on the authority of Avalon Ctr. v. Hardaway, 967 So.2d 268, 271 (Fla. 1st DCA 2007). We agree, and hold that assertion of this jurisdictional defense (codified at section 440.13(ll)(c), Florida Statutes (1994)) is a de facto concession by the Employer/Carrier (E/C) that the services or products billed were provided by an authorized…