The never-ending dispute on this issue continues.
The Fifth District ruled that a provider could apply the PIP deductible to the entire bill first, and then subject the remaining bill to the applicable PIP fee schedule. This methodology will typically yield a greater recovery of benefits for the provider, which means a greater insurance payment. The case is found here:
The Fourth District came to the opposite conclusion certifying conflict providing that the total bill is reduced by the applicable fee schedule that typically provides less recovery of benefits for the provider and a lesser insurance payment. The case may be found here: https://edca.4dca.org/DCADocs/2016/2254/162254_1709_03142018_10043959_i.pdf