Residential facility is "hospital" in group medical policy dispute

A residential facility that treated preadolescent children suffering from functional nervous disorders was considered to be a "hospital" for purposes of coverage under a group medical insurance policy, despite the fact that it lacked an on-premises surgical facility and did not provide 24-hour nursing services by registered nurses. The insurance company had waived the surgical facility requirement. Additionally, since the policy in question did not contain a definition of "nursing services," there was no requirement that these services be provided 24 hours a day by registered nurses. Thus the insureds were entitled to coverage of the treatment for their son in the residential facility. But a bad faith claim was denied because the insurer's interpretation of its policy was not found to be unreasonable.