ILCS » Chapter 770 · Act 23
Illinois Compiled Statutes

770 ILCS 23/45 (2026)

Amounts not recovered under lien

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(770 ILCS 23/45)
    Sec. 45. Amounts not recovered under lien. Nothing in this Act shall be construed as limiting the right of a health care professional or health care provider, or attorney, to pursue collection, through all available means, of its reasonable charges for the services it furnishes to an injured person. Notwithstanding any other provision of law, a lien holder may seek payment of the amount of its reasonable charges that remain not paid after the satisfaction of its lien under this Act.
(Source: P.A. 93-51, eff. 7-1-03.)

    
Notes of Decisions
Cited in 10 cases, 2007–2017 · leading case: Wendling v. S. Illinois Hosp. Servs., 950 N.E.2d 646 (Ill. 2011).
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Wendling v. S. Illinois Hosp. Servs., 950 N.E.2d 646 (Ill. 2011). · cites it 2× “770 ILCS 23/45 (West 2008). Where the total liens filed under the Act amount to 40% of the judgment or settlement, the total amount of attorneys’ liens under the Attorneys Lien Act (770 ILCS 5/0.”
Jayko v. Fraczek, 966 N.E.2d 1121 (Ill. App. Ct. 2012). · cites it 2× “2d 910, 914 (2007) (quoting 770 ILCS 23/45 (West 2004) ("Nothing in this Act shall be construed as limiting the right of a health care professional or health care provider, or attorney, to pursue collection, through all available means, of its reasonable charges for services it…”
Jayko v. Fraczek, 2012 IL App (1st) 103665 (Ill. App. Ct. 2012). “) (quoting 770 ILCS 23/45 (West 2004))). ¶8 Section 10(b) of the Act specifies the contents of a health care provider’s lien and indicates its “written notice” is effective whether delivered by mail or tendered in person: “The lien shall include a written notice containing the…”
Progressive Universal Ins. v. Taylor, 874 N.E.2d 910 (Ill. App. Ct. 2007). “” 770 ILCS 23/45 (West 2004). Carle reasons as follows: “[T]he request for turn[ ]over of [the medical-payments] proceeds conforms with the intent of medical[-]payments coverage in reimbursing medical providers for services rendered to injured (and insured) parties involved in…”
Barry v. St. Mary's Hosp. Decatur, 2016 IL App (4th) 150961 (Ill. App. Ct. 2017). “” 770 ILCS 23/45 (West 2012). ¶ 59 Thus, St.”
Barry v. St. Mary's Hosp. Decatur, 2016 IL App (4th) 150961 (Ill. App. Ct. 2016). “” 770 ILCS 23/45 (West 2012). ¶ 59 Thus, St.”
Howell v. Dunaway, 924 N.E.2d 1190 (Ill. App. Ct. 2010). · cites it 2× “770 ILCS 23/45 (West 2008). Both the plaintiffs were injured in motor vehicle accidents and were treated in one or more of the respondent hospitals.”
Wendling v. S. Illinois Hosp. Servs. (Ill. 2011). · cites it 2× “770 ILCS 23/45 (West 2008). Where the total liens filed under the Act amount to 40% of the judgment or settlement, the total amount of attorneys’ liens under the Attorneys Lien Act (770 ILCS 5/0.”
Howell v. Dunaway (Ill. App. Ct. 2010). · cites it 2× “770 ILCS 23/45 (West 2008). Both the plaintiffs were injured in motor vehicle accidents and were treated in one or more of the respondent hospitals.”
Progressive Universal Ins. Co. v. Taylor (Ill. App. Ct. 2007). “" 770 ILCS 23/45 (West 2004). Carle reasons as follows: "[T]he request for turn[]over of [the medical-payments] proceeds conforms with the intent of medical[-]payments coverage in reimbursing medical providers for services rendered to injured (and insured) parties involved in…”
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