Conn. Gen. Stat. » Title 52 — CIVIL ACTIONS · Chapter 899 — Evidence
Connecticut General Statutes

Conn. Gen. Stat. § 52-184b (2026)

Failure to bill and advance payments inadmissible in malpractice cases

✓ current as of May 2026
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(a) For the purposes of this section, “health care provider” means any person, corporation, facility or institution licensed by this state to provide health care or professional services, or an officer, employee or agent thereof acting in the course and scope of his employment.

(b) The failure of a health care provider to bill a patient for services rendered shall not be construed as an admission of liability and shall not be admissible in evidence as to liability in any trial for malpractice, error or omission against a health care provider in connection with the provision of health care or professional services.

(c) Any advance payment for medical bills by a health care provider or by the insurer of a health care provider shall not be construed as an admission of liability and shall not be admissible in evidence as to liability in any trial for malpractice, error or omission against a health care provider in connection with the provision of health care or professional services.

(P.A. 76-125, S. 1–3.)

Cited. 211 C. 555; 242 C. 1.

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Notes of Decisions
Cited in 22 cases (2 in the last 5 years), 1994–2023 · leading case: DiLieto v. Cnty. Obstetrics & Gynecology Grp., P.C., 828 A.2d 31 (Conn. 2003).
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DiLieto v. Cnty. Obstetrics & Gynecology Grp., P.C., 828 A.2d 31 (Conn. 2003). · cites it 12× “The defendants respond that the trial court properly precluded Shepherd from testifying because he was not “a health care provider” pursuant to § 52-184c, which incorporates by reference the definition of health care provider found in General Statutes § 52-184b. 13 Section…”
Bruttomesso v. Ne. Connecticut Sexual Assault Crisis Servs., Inc., 698 A.2d 795 (Conn. 1997). · cites it 7× “In defining a cause of action against a health care provider, § 52-184c incorporates the definition of health care provider set forth in General Statutes § 52-184b, which, in turn, provides that a health care provider “is any person, corporation, facility or institution licensed…”
Trimel v. Lawrence & Mem'l Hosp. Rehab. Ctr., 764 A.2d 203 (Conn. App. Ct. 2001). · cites it 4× “2 The plaintiff also concedes that if this court concludes that her claim was correctly classified as a medical malpractice claim, then the trial court’s order was proper because she did not file a certificate of good faith.”
Ali v. Cmty. Health Care Plan, Inc., 801 A.2d 775 (Conn. 2002). · cites it 3× “) General Statutes § 52-184b (a). Thus, under the statute, the relevant health care provider in the case could have been either the defendant, *153 as the corporate entity providing health care services to the plaintiff, or Brekus-Watson, as the individual caregiver and an…”
Gold v. Greenwich Hosp. Ass'n, 811 A.2d 1266 (Conn. 2002). “General Statutes § 52-184c (a) provides: “In any civil action to recover damages resulting from personal injury or wrongful death occurring on or after October 1,1987, in which it is alleged that such injury or death resulted from the negligence of a health care provider, as…”
Bennett v. New Milford Hosp., Inc., 12 A.3d 865 (Conn. 2011). “2 General Statutes § 52-184c provides; “(a) In any civil action to recover damages resulting from personal injury or wrongful death occurring on or after October 1,1987, in which it is alleged that such injury or death resulted from the negligence of a health care provider, as…”
Plante v. Charlotte Hungerford Hosp., 12 A.3d 885 (Conn. 2011). “” 12 General Statutes § 52-184c provides: “(a) In any civil action to recover damages resulting from personal-injury or wrongful death occurring on or after October 1,1987, in which it is alleged that such injuiy or death resulted from the negligence of a health care provider,…”
Dias v. Grady, 972 A.2d 715 (Conn. 2009). “6 General Statutes § 52-184c provides: “(a) In any civil action to recover damages resulting from personal injury or wrongful death occurring on or alter October 1,1987, in which it is alleged that such injury or death resulted from the negligence of a health care provider, as…”
Smith v. Andrews, 959 A.2d 597 (Conn. 2008). “13 General Statutes § 52-184c (a) provides: “In any civil action to recover damages resulting from personal injury or wrongful death occurring on or after October 1,1987, in which it is alleged that such injury or death resulted from the negligence of a health care provider, as…”
Grondin v. Curi, 817 A.2d 61 (Conn. 2003). “General Statutes § 52-184c provides: “(a) In any civil action to recover damages resulting from personal injury or wrongful death occurring on or after October 1,1987, in which it is alleged that such injury or death resulted from the negligence of a health care provider, as…”
Wilkins v. Connecticut Childbirth & Women's Ctr., 42 A.3d 521 (Conn. App. Ct. 2012). · cites it 3× “General Statutes § 52-184b (a). “Thus, under the statute, the relevant health care provider in the case could have been either the defendant, as the corporate entity providing health care services to the plaintiff, or .”
Labissoniere v. Gaylord Hosp., Inc., 185 A.3d 680 (Conn. App. Ct. 2018). “in which it is alleged that such injury or death resulted from the negligence of a health care provider, as defined in section 52-184b, the claimant shall have the burden of proving by the preponderance of the evidence that the alleged actions of the health care provider…”
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