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 Courts have developed a variety of approaches. These approaches have been grouped into three categories: (1) actual amount paid, (2) benefit of the bargain, and (3) reasonable value. See, e.g., Stayton v. Del. Health Corp., 117 A.3d 521, 527 (Del. 2015); Wills, 892 N.E.2d at 1025; Bozeman, 879 So. 2d at 701. 

A minority of courts follow the 'actual amount paid' approach urged by the Defendants in this appeal. The 'actual amount paid' approach limits a plaintiff's recovery to the amount actually paid to the medical provider, either by insurance or otherwise. See Wills, 229 Ill. 2d 393, 892 N.E.2d 1018, 1025-26, 323 Ill. Dec. 26. Courts following this approach generally seek to avoid allowing plaintiffs any so-called 'windfall' from tortfeasors. Id. They take the position that limiting plaintiffs' recovery to the amount paid to the medical provider is not contrary to the collateral source rule because the rule is not implicated. When insurance payments are used to compensate the plaintiff's medical providers, they reason, limiting the plaintiff's recovery to only the amount actually paid by the insurance company to the medical provider simply permits the plaintiff to recover no more than he ...

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