[J-23-2024]
                   IN THE SUPREME COURT OF PENNSYLVANIA
                              WESTERN DISTRICT


 ELITE CARE, RX, LLC                            :   No. 25 WAP 2023
                                                :
              v.                                :   Appeal from the Order of the
                                                :   Superior Court entered May 23,
 PREMIER COMP SOLUTIONS, LLC;                   :   2023 at No. 1144 WDA 2020,
 LAUNDRY OWNERS’ MUTUAL LIABILITY               :   affirming the Order of the Court of
 INSURANCE ASSOCIATION; UPMC                    :   Common Pleas of Allegheny County
 BENEFIT MANAGEMENT SERVICES, INC.              :   entered June 5, 2020 at No. GD-19-
 D/B/A UPMC WORK PARTNERS;                      :   005312 and remanding.
 LACKAWANNA CASUALTY COMPANY;                   :
 AND BRICK STREET MUTUAL                        :   ARGUED: April 9, 2024
 INSURANCE COMPANY                              :
                                                :
 APPEAL OF: PREMIER COMP                        :
 SOLUTIONS, LLC AND BRICK STREET                :
 MUTUAL INSURANCE COMPANY                       :


                        OPINION IN SUPPORT OF REVERSAL


JUSTICE WECHT                                                 DECIDED: JULY 17, 2024
      The Superior Court below affirmed a decision allowing a lawsuit for fraud, civil

conspiracy, and unjust enrichment to proceed against workers’ compensation insurance

carriers that allegedly failed to reimburse providers for medications dispensed to injured

workers. As I detail below, that holding plainly conflicts with the Workers’ Compensation

Act’s exclusive remedy provision and was based upon a misunderstanding of the Act’s

fee review provision. The Superior Court’s decision should be reversed.
                                I. Statutory Background

       Under the Workers’ Compensation Act, employers and their insurers are liable for

a claimant’s reasonable medical expenses, which includes medication and medical

supplies.1 Generally speaking, disputes about medical expenses can be litigated three

different ways within the workers’ compensation system: utilization review, penalty

petitions, and fee review.

       Utilization review can be used by employers to challenge the reasonableness or

necessity of a billed service, or by providers to secure pre-approval from the insurer for a

medical service.2 When a request for utilization review is made, an impartial “provider

licensed in the same profession and having the same or similar specialty as that of the

provider of the treatment under review” will consider the reasonableness and necessity

of the treatment and render a decision.3 A party who disagrees with the outcome of the

utilization review can appeal the determination to a Workers’ Compensation Judge, and

then eventually to the Commonwealth Court as well.4

       Penalty petitions arise in a different context. A claimant who believes that their

employer has failed to satisfy its statutory obligation to pay necessary medical expenses

can file a penalty petition, which will then be decided by a WCJ. Unlike utilization review,

which medical providers can initiate themselves, it is only the claimant that can file a

penalty petition. This avenue therefore may be of limited utility to medical providers



1      77 P.S. § 531(1)(i) (“The employer shall provide payment in accordance with this
section for reasonable surgical and medical services, services rendered by physicians or
other health care providers, including an additional opinion when invasive surgery may
be necessary, medicines and supplies, as and when needed.”).
2      77 P.S. § 531(6).
3      Id. § 531(6)(i).
4      Id. § 531(6)(iv).


                                      [J-23-2024] - 2
whenever the claimant is unmotivated to file a penalty petition against their employer for

one reason or another.5

       Fee review is the third avenue for billing challenges. Under a provision of the Act

passed in 1993, providers can challenge the “amount or timeliness” of the insurer’s

payment by filing a fee review application. Fee review applications are first decided

administratively by the Bureau of Workers’ Compensation, but either party can take a de

novo appeal to a special fee review hearing officer.6 The hearing officer’s ruling can then

be appealed to the Commonwealth Court. This process is governed by Subsection

306(f.1)(5) of the Act, which states that

       [a] provider who has submitted the reports and bills required by this section
       and who disputes the amount or timeliness of the payment from the
       employer or insurer shall file an application for fee review with the
       department no more than thirty (30) days following notification of a disputed
       treatment or ninety (90) days following the original billing date of treatment.7



5       One could imagine reasons why a claimant who is receiving wage-loss benefits
under the Act might be reluctant to initiate adversarial proceedings against their employer
primarily for the benefit of a medical provider. For example, a claimant in an uncontested
case who is in the process of negotiating a settlement with their employer might opt to
forego seeking penalties. A claimant who expects to return to work with their employer
post-recovery may be similarly apprehensive about filing a penalty petition. That said,
the Act incentivizes claimants to file penalty petitions by imposing monetary penalties on
employers who fail to make required payments—with such penalties being payable to the
claimant. 77 P.S. § 991(d)(i) (stating that employers may be penalized up to ten percent
of the amount awarded (or up to fifty percent if the delay was “unreasonable or excessive”)
and that any penalties are “payable to the same persons to whom the compensation is
payable”).
6       It is my understanding that these fee review hearing officers are sometimes
(though not always) WCJs wearing different hats. See Prescription Partners, LLC v.
Bureau of Workers’ Comp. Fee Rev. Hearing Off., No. 2107 C.D. 2014, 

, at *1 (Pa. Commw. July 17, 2015) (Cohn Jubelirer, J., concurring) (noting that
“the Hearing Officer in the instant matter was a Workers’ Compensation Judge” acting in
a different capacity).
7      77 P.S. § 531(5).


                                       [J-23-2024] - 3
       The Act elsewhere defines a “provider” as a “healthcare provider,” which in turn is

defined to mean:

       any person, corporation, facility or institution licensed or otherwise
       authorized by the Commonwealth to provide health care services, including,
       but not limited to, any physician, coordinated care organization, hospital,
       health care facility, dentist, nurse, optometrist, podiatrist, physical therapist,
       psychologist, chiropractor or pharmacist and an officer, employe or agent
       of such person acting in the course and scope of employment or agency
       related to health care services.8
       This Court has emphasized that fee review is designed to be a simple process with

“a very narrow scope.”9 That scope is limited to determining the “relatively simple matters”

of “‘the amount or timeliness’ of an insurer’s payment for a particular treatment.”10 This

means that “an employer’s liability for a claimant’s work injury must be established before

the fee review provisions can come into play.”11

                     II. Case Law Interpreting Subsection 306(f.1)(5)

       As I detail below, a trio of Commonwealth Court decisions in the mid-2010s

injected unnecessary confusion into the fee review system. That confusion ultimately

dissipated in 2019, when the Commonwealth Court, sitting en banc, overruled those three

earlier decisions. While this should have resolved the matter, the Superior Court below

opted to embrace the Commonwealth Court’s since-discarded line of precedent, ignoring

the difficult lessons learned by the Commonwealth Court in the previous decade.

       The first of these three erroneous decisions concerned whether a provider billing

a workers’ compensation insurer was the same entity that rendered the care to the


8      77 P.S. § 29.
9      Crozer Chester Med. Ctr. v. Dept. of Lab. & Indus., 

 (Pa. 2011).
10     

.
11    Armour Pharmacy v. Bureau of Workers’ Comp. Fee Rev. Hearing Off., 

 (Pa. Commw. 2019) (emphasis added).


                                       [J-23-2024] - 4
claimant in the first place. The first-level fee reviewer initially ordered the insurer to pay

the provider’s bills, but the fee review hearing officer ruled on appeal that the Bureau

lacked jurisdiction over the dispute because it did not concern the “amount or timeliness”

of payment, but instead concerned whether the provider (an entity called the Physical

Therapy Institute) was a provider under the Act. On further appeal, the Commonwealth

Court agreed with the hearing officer, holding that fee review is not the proper forum to

resolve an entity’s provider status.12

       The Commonwealth Court reaffirmed this holding the following year in a case

involving the same parties. In Physical Therapy Institute, Inc. v. Bureau of Workers’

Compensation Fee Review Hearing Office, 

 (Pa. Commw. 2015), the

Institute explicitly asked the court to overturn its 2014 holding. The Institute emphasized

that, if the court’s ruling stands, all an insurer participating in fee review would have to do

is assert—whether true or not—that the person or entity submitting the bill is not a provider

under the act. Under the Commonwealth Court’s interpretation, that mere allegation

would render the Bureau and the fee review hearing officer jurisdictionless to consider

the dispute. And because un/underpaid providers lack standing to file penalty petitions

directly with the WCJ, the provider’s only recourse would be to encourage the claimant to

seek penalties against their employer.

       Declining to overturn the 2014 decision, the court reiterated that whether an entity

is a provider under the Act is “a question of liability, which is beyond the scope of a fee

review and must be decided by a Workers’ Compensation Judge.”13 As for the argument


12     Selective Ins. Co. of Am. v. Bureau of Workers’ Compensation Fee Review
Hearing Off., 

 (Pa. Commw. 2014) (overruled by Armour Pharmacy, 

).
13    Physical Therapy Inst., Inc. v. Bureau of Workers’ Compensation Fee Review
Hearing Off., 

 (Pa. Commw. 2015).


                                         [J-23-2024] - 5
that the court’s interpretation would allow insurers to undermine the entire fee review

process just by challenging a biller’s provider status, the court stated that providers still

have “recourse” inasmuch as claimants always can “file a [penalty] petition to establish

[an] insurer’s liability.”14

        The third case in this line of precedent, also from 2015, involved a physician who

was dispensing pain medications from his own office.15 When doing this, the physician

would “repackage” the medications and assign them new National Drug Codes that

significantly increased the insurer’s reimbursement cost. The physician never billed the

workers’ compensation insurer directly for the medications; instead, he assigned the

claims to an entity called Prescription Partners, which then billed the insurer. When the

insurer refused to pay the full cost of the repackaged drugs, Prescription Partners initiated

fee review proceedings. The first-level administrative analyst concluded that Prescription

Partners was not a provider under the Act and therefore lacked standing to initiate fee

review.       Prescription Partners then unsuccessfully appealed that determination to a

Hearing Officer.

        On further appeal, the Commonwealth Court cited the two cases discussed above

and reiterated that the Bureau and its fee review hearing officers lack “jurisdiction to

determine whether an entity is a ‘provider’ of medical services, or simply a billing

agency.”16 The court stated that provider status “is a question of liability, which is beyond

the scope of a fee review and must be decided by a Workers’ Compensation Judge.”17

In a concurrence, Judge Cohn Jubelirer conceded that the majority “is not incorrect based


14      

.
15      Prescription Partners, LLC, 

, at *1.
16      

 at 3 (quoting Physical Therapy Inst., 

).
17      

                                       [J-23-2024] - 6
on existing precedent,” but she nevertheless suggested that “reconsideration of those

cases appears appropriate.”18

      The Commonwealth Court’s holding in the above cases that the Bureau and its fee

review hearing officers lack jurisdiction to consider the threshold issue of whether an

entity is a provider unquestionably conflicts with the legislature’s intent when it created

the fee review process. As Workers’ Compensation Judge and treatise author David B.

Torrey has explained:

      Under [1993 amendments to the Act], jurisdiction over disputes regarding
      amount and timeliness of payment by carriers to providers was taken away
      from WCJs. In substitution, administrative review was introduced, with any
      appeal de novo to a special hearing officer. The injured worker was not to
      be involved. The idea was to expedite disputes that occur in the program
      when the injured worker is not involved, but where, instead, the dispute is
      only a technical one regarding the correct amount to be reimbursed. And,
      of course, the Act mandates that all providers who treat workers’
      compensation claimants are bound by the provisions of the Act; the law
      prohibits providers from direct-billing and balance-billing injured workers;
      and, generally, providers have no standing to file petitions directly with a
      WCJ to get their bills paid.

      A controversy was injected into this system in the wake of three decisions
      (one in 2014 and two in 2015), from the Commonwealth Court restricting
      the Fee Review Hearing Officer to deciding only issues of the amount and
      timeliness of bills. Via these rulings, the Hearing Officer was prohibited from
      determining the basic issue of standing. In turn, this left two entities—one
      a billing agent, and the other a claim assignee—without recourse in the fee
      review system to complain of unsatisfactory payment, until a WCJ resolved
      any challenge to the entity’s identity as a “provider.”

      An irony was thus created under the Pennsylvania practice: the 1993 reform
      forces physicians and other providers to work within the system (no direct
      billing of the injured worker, for example, is permitted), but then left at least
      some of them without an effective, cost-efficient remedy to secure payment.
      In a further irony, the solution was for the provider to encourage the injured
      worker, who was intended to be left out of the controversy, to file a petition
      with a WCJ in the conventional track of litigation.


18    Id. at *5 (Cohn Jubelirer, J., concurring).


                                      [J-23-2024] - 7
      Critics of the regime created by these cases complained that provider
      “payment can be stymied by carrier/employer pretextually denying
      causation and the fact that the party seeking relief is in fact a ‘provider.’” R.
      Burke McLemore, a leading critic of this school, admonished, “By the simple
      expedient of denying either causation or status as a provider, a
      carrier/employer can completely thwart reimbursement to a provider of
      legitimate bills—and then go ahead and settle the case with (or without) any
      admission of liability and leaving the provider hanging and without any
      effective remedy.”19
      Fortunately, the Commonwealth Court overruled this line of precedent in 2019. In

Armour Pharmacy v. Bureau of Workers’ Comp. Fee Review Hearing Office, 

 (Pa. Commw. 2019), the Commonwealth Court held that “where the employer

challenges a fee determination of the Medical Fee Review Section for the stated reason

that the medical service was not rendered by a ‘provider’ within the meaning of the Act,

that threshold question must be decided by the Hearing Office.”20 The court nevertheless

cautioned that its holding does not “expand the scope of the fee review proceeding

beyond timeliness and amount owed to a provider that has treated a claimant for his work

injury.”21 The decision in Armour Pharmacy was never appealed to this Court.

                                 III. The Decision Below

      This appeal concerns prescriptions that injured employees had filled by a home-

delivery pharmacy called Patient Direct RX. Behind the scenes, Patient Direct does not

operate as a typical pharmacy would. When Patient Direct fills an injured workers’

prescription, it does not simply bill the workers’ compensation insurance carrier for the




19    DAVID B. TORREY & ANDREW E. GREENBERG, WORKERS’ COMPENSATION: LAW AND
PRACTICE § 9:157 (West 2022) (emphasis in original; footnotes omitted).
20    Armour Pharmacy, 

.
21    

 (“This holding does not allow the Hearing Office to determine the
reasonableness of the medical care or service; the claimant’s injury as work-related; or
the employer’s liability for a work injury.”).


                                      [J-23-2024] - 8
medication; instead, it sells to the treating physician who wrote the prescription in the first

place the right to bill the workers’ compensation insurer.

       Appellee Elite Care, RX, LLC is a billing agent for some of the medical providers

who purchased claims from Patient Direct RX. When Elite Care tried to collect payment

on behalf of its providers, the appellant Insurers took the position that Elite Care is not a

provider under the Act and refused payment. In total, Insurers denied payment for 110

different injured employees’ medications, resulting in $548,035.28 in unpaid

prescriptions. When Elite Care’s invoices went unpaid, it initiated many separate fee-

review proceedings with the Bureau. The Bureau ruled in favor of Elite Care in some of

the cases, and the Insurers appealed some of those decisions to fee review hearing

officers, arguing that the Bureau lacked jurisdiction to determine Elite Care’s status as a

provider. The hearing officers agreed with Insurers that the Bureau lacked jurisdiction

over Elite Care’s fee review applications.

       Elite Care did not appeal those adverse decisions to the Commonwealth Court.

Instead, Elite Care filed a civil lawsuit against Insurers alleging fraud, civil conspiracy, and

unjust enrichment. Elite Care also sought a declaratory judgment that it is a provider

under the Act. Insurers filed preliminary objections asserting the trial court lacked subject-

matter jurisdiction over the dispute because Elite Care’s exclusive remedy lies in the

workers’ compensation system. The trial court overruled Insurers’ preliminary objections,

reasoning that the case is not a workers’ compensation case but rather a claim for

damages arising from Insurers’ alleged fraud and conspiracy.22 A three-judge panel of



22      Trial Court Opinion, 12/28/2020, at 2 (“This case is not a workers’ compensation
matter. It is a declaratory judgment and damages case alleging that insurers and their
administrator engaged in fraud and civil conspiracy by refusing to pay Elite [Care] money
it is owed for medicine supplied to certain insured persons. Such a case is within the
jurisdiction of this court.”).


                                        [J-23-2024] - 9
the Superior Court unanimously affirmed the trial court and Insurers then successfully

petitioned for en banc review.23

         The en banc court affirmed the trial court, offering essentially three rationales for

its decision24 First, the court noted that “Elite Care’s three common-law causes of action

clearly predate the [Workers’ Compensation Act] and have been under the subject-matter

jurisdiction of the courts of common pleas since time immemorial.”25 Second, the court

emphasized that there is “nothing in the current Workers’ Compensation Act granting the

Bureau jurisdiction over” the kinds of tort claims that Elite Care alleged in its complaint.26

Lastly, the panel declined to follow Armour Pharmacy, accusing Commonwealth Court in

that case of “manufacturing” an “administrative proceeding for a putative provider to seek

redress within the Bureau.”27 Criticizing the Armour Pharmacy Court for what it called

“legislating from the bench,” the majority opined that the Commonwealth Court created:

         an administrative proceeding for putative providers by bestowing a [sic]
         jurisdiction upon Bureau Hearing Officers. That proceeding and jurisdiction
         cannot be found in the language of the [Workers’ Compensation Act].
         Therefore, we decline to follow Armour Pharmacy, in so far as it stands for
         the proposition that Elite Care may or should have sought redress within the
         Bureau.

         Simply stated, the Worker’s Compensation Act does not provide for an
         administrative proceeding by or against putative providers or their billing
         agents in the Bureau. Such entities have no standing there, because the
         [Act] does not confer it upon them. That statute has not divested the original


23    See Elite Care, Rx, LLC v. Premier Comp Solutions, LLC, 

 (Pa.
Super. 2022).
24       Elite Care, Rx, LLC v. Premier Comp Solutions, LLC, 

 (Pa. Super.
2023).
25       

.
26       

27       

                                       [J-23-2024] - 10
       jurisdiction of the courts of common pleas over matters such as the instant
       lawsuit.28
                                     IV. Discussion

       The decision below plainly conflicts with the Workers’ Compensation Act’s

exclusive remedy provision, which this Court has held “extends to [the] workers’

compensation insurance carrier, protecting the insurer to the full extent of the employer’s

protection.”29 Because the employer/insurer’s obligation to pay the claimant’s medical

expenses arises from the Workers’ Compensation Act in the first place, the workers’

compensation system is the exclusive forum for resolving both payment disputes and

alleged mismanagement of workers’ compensation claims.30

       The Superior Court’s rationale for departing from this well-established rule is

unpersuasive. The panel first reasoned that “Elite Care’s three common-law causes of

action” are cognizable in the trial court because the tort claims in question “predate” the

1915 Workers’ Compensation Act “and have been under the subject-matter jurisdiction of

the courts of common pleas since time immemorial.”31 Even Elite Care does not embrace

this legal theory. There is no support whatsoever for the idea that whether a tort claim is

barred by the exclusive remedy provision turns on whether the tort in question predates

the 1915 Workers’ Compensation Act. To the extent that the court believed that the



28     

.
29      Kuney v. PMA Ins. Co., 

 (Pa. 1990) (“An employer’s liability
for work-related injuries is governed solely by the [Workers’] Compensation Act, and the
same is true of a compensation insurance carrier.”); see 77 P.S. § 481(a) (“The liability of
an employer under this act shall be exclusive and in place of any and all other liability to
such employes, his legal representative, husband or wife, parents, dependents, next of
kin or anyone otherwise entitled to damages in any action at law or otherwise on account
of any [compensable] injury or death[.]” (footnote omitted)).
30     Kuney, 

.
31     Elite Care, Rx, 

.


                                     [J-23-2024] - 11
General Assembly only intended to bar civil suits for torts created after the enactment of

the Workers’ Compensation Act, the panel was simply mistaken.

       The court further underscored that “nothing in the current Workers’ Compensation

Act grant[s] the Bureau jurisdiction over” the specific common-law torts alleged in Elite

Care’s complaint.32 But that proves nothing. The reason why the Act does not give the

Bureau jurisdiction over claims of fraud and unjust enrichment against employers/insurers

in connection with their handling of workers’ compensation claims is simple: employers

and insurers have been given immunity from such claims in exchange for accepting the

remedies and obligations established in the Act.33 The absence of a statutory provision

giving the workers’ compensation authorities jurisdiction over a specific set of claims does

not mean that the General Assembly intended for those claims to proceed in the trial

court. Indeed, there is nothing in the Act granting the workers’ compensation authorities

jurisdiction over claims of negligence against employers. But that is not evidence that the

legislature intended for trial courts to hear negligence suits against employers; it is the

result of employers being immune from employee negligence suits.

       That leaves only the Superior Court’s theory that the exclusive remedy provision

does not bar Elite Care’s civil suit because the Workers’ Compensation Act only allows

providers (not putative providers) to seek administrative fee review. Of course, the

Commonwealth Court in Armour Pharmacy held that the Bureau does have jurisdiction to

decide provider status. And I have little doubt that Armour Pharmacy—at least broadly

speaking—was correctly decided. The Act’s fee-review provision merely states that “a

provider . . . who disputes the amount or timeliness of the payment from the employer or




32     

33     Kuney, 

.


                                     [J-23-2024] - 12
insurer shall file an application for fee review with the department.”34 While the statute

plainly limits participation in the fee review process to providers, it does not explicitly

preclude the Bureau from deciding the threshold issue of an applicant’s provider status.

The restriction is a judicial invention. Furthermore, to the extent that the statute is

ambiguous regarding the Bureau’s authority to decide whether a putative provider is in

fact a provider, the Superior Court’s chosen interpretation undoubtedly conflicts with the

legislature’s intent, which was to create an expedited fee-review process within the

workers’ compensation system that does not require the involvement of claimants.35

       To my mind, the only objectionable aspect of the Armour Pharmacy decision is

that it allows only fee review hearing officers to resolve challenges to a billing entity’s

provider status, meaning that first-level administrative reviewers cannot consider the

issue in the first instance.36 I concede that this piece of the Commonwealth Court’s

decision is not grounded in any statutory text and appears to be driven primarily by the

concern that those conducting the initial administrative review often lack legal training.37



34     77 P.S. § 531(5).
35      See DAVID B. TORREY & ANDREW E. GREENBERG, WORKERS’ COMPENSATION: LAW
AND PRACTICE § 9:157 (West 2022) (highlighting the irony that the Commonwealth Court’s
pre-Armour Pharmacy decisions left some putative providers “without an effective, cost-
efficient remedy to secure payment” while insisting that “the solution was for the provider
to encourage the injured worker, who was intended to be left out of the controversy, to
file a petition with a WCJ in the conventional track of litigation” (emphasis omitted)).
36      See Armour Pharmacy, 

 (“We hold that where the employer
challenges a fee determination of the Medical Fee Review Section for the stated reason
that the medical service was not rendered by a ‘provider’ within the meaning of the Act,
that threshold question must be decided by the Hearing Office. Jurisdiction, a quasi-
judicial matter, is not to be decided by the Medical Fee Review Section, whose
responsibility is solely administrative.”).
37     See generally Crozer Chester Med. Ctr., 

 (explaining that the fee
review process “is administered by nurses” whose “skills are markedly distinct from” those
of workers’ compensation judges).


                                     [J-23-2024] - 13
It is this part of Armour Pharmacy that I believe prompted the court below to accuse the

Commonwealth Court of “legislat[ing] from the bench.”38 Regardless, this Court need not

adopt Armour Pharmacy’s reasoning in toto to conclude that the Superior Court erred

below. It is enough to say that Armour Pharmacy was correct in abandoning the notion

that provider status “is a question of liability, which is beyond the scope of a fee review

and must be decided by a Workers’ Compensation Judge.”39 Whether challenges to an

entity’s provider status should be resolved in the first or the second level of the fee review

process is irrelevant. It is enough for our purposes today to say that nothing in the Act

prevents the issue of a putative provider’s standing from being resolved in fee review.

The Superior Court therefore erred in holding that the Act “does not provide for an

administrative proceeding by or against putative providers or their billing agents in the

Bureau.”40

       In sum, the decision below misinterpreted Subsection 306(f.1)(5) and created a

state of affairs that plainly conflicts with the Act’s exclusive remedy provision. Elite Care’s

sole remedy lies in the administrative realm. The lower courts therefore erred in allowing

Elite Care’s civil suit to proceed.

       I would reverse the Superior Court’s decision.

       Justice Brobson joins this opinion in support of reversal.




38     See Elite Care, Rx, LLC, 

 (accusing the Armour Pharmacy Court of
creating “an administrative proceeding for putative providers” that “cannot be found in the
language of the [Act]”).
39     Prescription Partners, LLC, 

, at *3.
40    Elite Care, Rx, LLC, 

 (stating that the Act “does not provide for an
administrative proceeding by or against putative providers or their billing agents in the
Bureau,” meaning that the statute “has not divested the original jurisdiction of the courts
of common pleas” over actions brought by putative providers).


                                      [J-23-2024] - 14