How has the court treated the issue of third party payments in medical malpractice cases?

Finally, this court again addressed the issue of medical damages in Uspenskaya v. Meline (2015) 241 Cal.App.4th 996 (Uspenskaya). There, as here, the plaintiff received medical treatment in exchange for a lien benefiting the providers, who later sold those liens to a third party for an amount less than that billed to the plaintiff for the services. (Id. at p. 999.) The trial court prevented defendant from introducing the amount the third party paid as evidence of the reasonable value of the medical services provided. (Ibid.) Uspenskaya noted that the payments by the third party may be relevant"they have a tendency in reason to prove reasonable value" (id. at p. 1002)but they were properly excluded as unduly prejudicial and potentially confusing because the amount paid "represents a reasonable approximation of the collectability of the debt rather than a reasonable approximation of the value of the plaintiff's medical services" (id. at p. 1003) and the defendant did not proffer any other evidence that the amount paid reflected a reasonable valuation of the medical services (id. at pp. 1003-1004).