---
title: "Determination of the Robinson v. Bates Number"
description: "The Robinson v. Bates number, drawn from a full review of medical bills and amounts paid by insurers and the plaintiff, gives one basis for early negotiation."
url: "https://excelas1.com/blog/determination-of-the-robinson-v-bates-number"
published: "2019-05-30"
updated: "2026-09-14"
type: "post"
---

# Determination of the Robinson v. Bates Number

_2019-05-30 · Filed under [Blog](https://excelas1.com/blog/categories/blog)_

> The Robinson number can be used as one basis for negotiations early in the evaluation process. A comprehensive review of all related medical bills, including but not limited to outpatient, inpatient, rehabilitation and physician bills, along with the amount paid by insurers and out of pocket by the plaintiff, is necessary.

The plaintiff in any tort action clearly seeks the highest possible payment as a result of their injury. A fact-finder, often a jury, decides what a reasonable payment should be. How this payment amount is calculated varies by state, but in the state of Ohio this determination is guided by the 2006 Ohio Supreme Court decision [_Robinson v. Bates_](http://www.supremecourt.ohio.gov/rod/docs/pdf/0/2006/2006-ohio-6362.pdf).

### Robinson v Bates Background

In the _Robinson_ case it was determined that both the amount originally billed by the provider and the amount paid by the insurer are admissible to prove the reasonable value of the medical treatment. In other words, the defense can introduce the amount of “write-offs”, or the negotiated paid-in-full amount, for consideration. The result of this ruling, allowing the introduction of the paid-in-full amount, is a decrease in the amount under consideration when determining compensation to the plaintiff.

The _Robinson_ ruling was reaffirmed in [_Jaques v. Manton_](https://caselaw.findlaw.com/oh-supreme-court/1523699.html) in 2010 and again in [_Moretz v. Muakkassa_](http://www.supremecourt.ohio.gov/rod/docs/pdf/0/2013/2013-ohio-4656.pdf) in 2013. In _Jaques_, the court’s opinion was that the reasonable value of medical services was a matter for a jury to determine from all relevant evidence. Write-offs are amounts not paid by third parties, or anyone else, so permitting introduction of evidence of them allows the jury (or fact-finder) to determine the actual amount of medical expenses incurred as a result of the defendant’s conduct. In _Moretz,_ the Supreme Court of Ohio again upheld the admissibility of write-off evidence. The Court held that “evidence of ‘write-offs,’ reflected in medical bills and statements is prima facie evidence of the reasonable value of medical services.”

### Using the Robinson Number to Decide Case Value

The _Robinson_ Number is used as one basis for negotiations early in the evaluation process. To determine the number, a comprehensive review of all medical records and corresponding medical bills is necessary. This includes, but is not limited to: outpatient, inpatient, rehabilitation, and physician bills, along with the amount paid by insurers and out of pocket by the plaintiff.

#### How Excelas Can Help

The experienced medical analysts at Excelas can evaluate all aspects of care, as well as billing and reimbursement. Key components of our review include all providers of care, amounts billed by each provider, amounts paid to each provider by insurers or other parties (_Robinson _number), and verification that the bill is related to the claim/injury/accident. We also identify any pre-existing conditions/incidents which may relate to the claim in question. The final report is an easy-to-use spreadsheet providing counsel with a quick way to assess all aspects of the plaintiff’s medical history and the billing and reimbursement details. This spreadsheet helps verify the correct value of the _Robinson_ Number.

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