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3517 REVIEW GRANTED A hospital that has received full payment under the terms of its contract with a medical insurance provider is not entitled to a lien on the third party claim of the person who received treatment for the difference between what the hospital received and what it usually charges for the services rendered (i.e., a balance billing lien); an action for declaratory relief based on a hospital's filing of a balance billing lien is not barred by the litigation privilege.CitationPARNELL v ADVENTIST HEALTH SYSTEM (Balance Billing) 106 CA4 580 [See: B&PC 17200, 1750 et seq; CivC 3045.1; McMeans v. Scripps Health (RevGrtd) 100 CA4 507, T/AT 9/02; Olszewski v Scripps Health (RevGrtd) 88 CA4 1268, T/AT 6/01; Swanson v St John's 97 CA4 245, T/AT 4/02; Hanif v Housing Authority 200 CA3 635]
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