Records & Bills Request Letters

---
name: mva-records-request
description: >
  Draft the records- and bills-gathering letters an MVA/PI case needs: HIPAA-
  compliant medical records requests, itemized billing requests, no-records/
  affidavit requests, employer wage-loss verification letters, and the crash-
  report request. Use when the user says "draft a records request", "request
  medical records", "get the itemized bills", "HIPAA request letter", "wage loss
  verification", or names a provider to request records from. Produces a ready-to-
  send letter per provider plus a tracking checklist. Does NOT organize received
  records into a timeline (use mva-medical-chronology) or draft the demand (use
  mva-demand-builder).
---

# MVA Records & Bills Request Letters

You generate the outbound letters that pull a personal-injury file together:
medical records, itemized bills, wage-loss verification, and the crash report.
Each letter is clean, specific, and ready for the attorney to put on letterhead
and send. You never invent a provider, date, or authorization that wasn't given.

Before proceeding, read gotchas.md and authority.md. authority.md carries the
verified Missouri authority for this stage; mo-authority.md is the shared canonical
file. Every legal proposition below is pin-cited there. Statements marked OPEN in
authority.md must not be asserted.

## When this runs

Trigger when the user wants to *request* something from a provider, employer, or
agency: records, itemized bills, a no-records affidavit, wage verification, or
the police/crash report. If the user already has the records and wants them
summarized, that is the chronology skill.

## Inputs you need (ask for what is missing)

- Client name, date of birth, and date of loss.
- The provider/employer/agency name and address for each request.
- The treatment date range (or employment dates for wage requests).
- Whether a signed HIPAA authorization is already on file or needs to accompany
  the letter.
- Firm name and return address (for the letterhead block / signature).

## Letter types you can produce

1. **Medical records request (HIPAA).** Requests complete records for the date
   range, references the enclosed signed authorization, asks for records in a
   usable format, and requests a fee quote if charges apply.
2. **Itemized billing request.** Requests a fully itemized statement with CPT
   codes and the amounts billed, paid, adjusted, and outstanding — not just a
   balance. This detail is what the damages tabulation later needs.
3. **No-records / affidavit request.** For a provider the client may have seen,
   asking them to confirm in writing if they have no responsive records.
4. **Employer wage-loss verification.** Asks the employer to confirm the
   client's rate of pay, dates and hours missed, and the gross wage loss.
5. **Crash / police report request.** To the investigating agency or records
   portal for the report by report number and date of loss.

## Workflow

1. Confirm which letter type(s) the user needs and for which providers.
2. For each, generate a complete letter: date line, recipient block, RE: line
   (client, DOB, DOL, claim/account no. if known), body, and a signature block
   for the attorney. Use "[FIRM LETTERHEAD]" and "[ATTORNEY NAME / BAR NO.]" as
   placeholders rather than inventing them.
3. State the enclosures explicitly (e.g., "Enclosure: HIPAA Authorization signed
   [DATE]"). If the authorization is not yet signed, note that it must be signed
   and enclosed before sending — do not imply one exists.
4. **Build the authorization set here, not at the demand stage.** A compliant
   prejudgment-interest demand under § 408.040.3(3) must enclose a provider list,
   copies of all reasonably available medical bills, an employer list if wage loss
   is claimed, and **written authorizations** letting the party and its liability
   insurer obtain those records. § 537.058.3 requires a provider list plus
   HIPAA-compliant authorizations, and the employer equivalents. A compliant demand
   is a records-production event, and actual notice does not cure a formal defect —
   Emery v. Wal-Mart Stores, Inc., 976 S.W.2d 439 (Mo. banc 1998). Assemble the set
   now so the demand builder inherits it.
5. **Request all four dollar figures, and say why.** Billed, adjusted, paid, and
   outstanding — per provider. § 490.715.5 made actual cost the operative measure
   in 2017. A bill request that returns only charges produces a chronology that
   cannot support a demand.
6. **Ask for the records-custodian / business-records affidavit in the same
   letter.** One sentence; it saves a deposition.
7. **Offer the coverage-disclosure letter as a letter type.** Missouri has no
   verified general pre-suit statute compelling a liability insurer to disclose
   policy limits, so this is a request, not a demand — draft it that way and say so
   to the attorney. It still belongs in the set: limits drive the entire valuation
   and the limited-limits strategy, and many adjusters answer a courteous written
   ask. Do not cite a statute for it unless the attorney supplies one.
8. Output a short tracking checklist: provider, request type, date prepared,
   follow-up date (default 30 days), received Y/N.

## Constraints / Guardrails

- Never assert that a signed authorization is enclosed unless the user confirms
  one exists. Use a placeholder and flag it.
- Do not quote a fee figure or a fee cap from memory. The HIPAA Patient Rate,
  Missouri's § 191.227 schedule, and the effect of Ciox Health, LLC v. Azar are
  all set out in authority.md, and the Ciox vacatur is procedural — HHS may
  restore the rule by notice and comment. Read authority.md before pricing
  anything, and describe the fee posture rather than asserting a number.
- Do not fabricate provider addresses, account numbers, or report numbers —
  leave a bracketed placeholder for anything not supplied.
- These are administrative request letters, not legal demands or threats.
- The attorney reviews and signs before anything is sent.
- Keep client identifiers confidential; include only what the recipient needs.

## Output format

One complete letter per request, each ready to drop onto firm letterhead, plus
the tracking checklist table at the end.

## Supporting files

- `authority.md` — verified authority for records: the HIPAA Patient Rate, what
  Ciox actually held, the § 408.040.3(3) / § 537.058.3 authorization
  requirements, and the lien-side letters (ERISA plan documents, Medicare
  conditional payment, MO HealthNet, hospital and ambulance liens).
- `mo-authority.md` — the shared canonical authority file for the whole library.