Shelby County Healthcare Corp., the Tennessee Court of Appeals concluded that, under Tennessee’s healthcare lien act, “the underlying debt to which the lien attaches is an obligation owed by the person receiving medical services from the hospital[,]” rather than an obligation owed by the tortfeasor or the tortfeasor’s insurer. 2013 WL 500777, *13 (Tenn.Ct. App.2013). The West court’s stance was that language in the agreement between the provider and insurer that attempted to reserve the provider a right to collect “appropriate amount(s) due ... from a third party that might have legal responsibility for the services rendered[,]” in spite of the same agreement’s hold harmless provision, was ineffective because the healthcare lien act “[did] not gi N.M. 417, 941 P.2d 498, 500-01 (1997) (<HOLDING>); Lopez v. Morley, 352 Ill.App.3d 1174, 288
holding that because the contract between the hospital and the health insurance company had a hold harmless provision which stated the hospital would not bill or hold insurance subscribers liable for any hospital expenses covered by the subscribers insurance contract and all expenses from the patients treatment for the automobile accident were covered in such contract there was no debt upon which the hospital could assert a lien pursuant to the states hospital lien statute holding that where hospital used balance billing that since the hospital had already received payments from the patient and his health insurer and had agreed to accept that amount as payment in full for its services there was no longer any amount owing to the hospital and thus it could not assert a statutory hospital lien for the difference between its charges and the amount received in light of the negotiated network agreements holding that a hospital may not assert a statutory lien in an amount exceeding the amount it agreed to accept from the patients insurer holding that under nebraskas physicians lien statute a physicians lien could not exceed the amount the health care provider agreed to accept for the services rendered to a patient even if the usual and customary charge for such services is greater than that sum because the statute extends such lien only to the amount due or debt of the patient to the hospital holding that a household exclusion in the policy was void insofar as it denied coverage in the amount required by  3031902 but it was valid as to any coverage exceeding that amount