MCG Health, Inc. v. Kight

While I concur fully with the majority, I write separately to emphasize that Constantine v. MCG Health, 275 Ga. App. 128 (619 SE2d 718) (2005) remains good law for the proposition that a hospital can contractually waive its right to collect on a hospital lien through a “no recourse” provision in the hospital’s contract with a patient’s health insurer.

In MCG Health v. Owners Ins. Co., 288 Ga. 782, 785 (1) (707 SE2d 349)(2011), the Supreme Court of Georgia held that OCGA § 44-14-470 (b) of the hospital lien statute does not require “that the debt... be owed by the patient in order for a…