May 14, 2021
Jodi Jacobs, D.C., PLLC v Global Liberty Ins. Co. of NY (2021 NY Slip Op 50445(U))
https://www.beynensonlaw.com/case-law/jodi-jacobs-d-c-pllc-v-global-liberty-ins-co-of-ny-2021-ny-slip-op50445u/
- Decided
- May 14, 2021
- Citation
- 2021 NY Slip Op 50445(U)
- Posture
- Summary judgment
- Outcome
- Split result
- Legal questions
- Proof of mailing · No-show defense: insurer's proof · Proving a fee schedule defense (see the maps)
Posture, outcome, issues and treatment by other decisions are Beynenson Law’s classification. Treatment labels are assigned by a language model reading the citing decision; negative and appeal-history labels are checked by a second reader.
Summary
Editorial summary by Beynenson Law, not part of the court’s decision.
Reported in New York Official Reports at Jodi Jacobs, D.C., PLLC v Global Liberty Ins. Co. of NY (2021 NY Slip Op 50445(U))
SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT, 2d, 11th and 13th JUDICIAL DISTRICTS
against
Global Liberty Ins. Co. of NY, Appellant.
Law Office of Jason Tenenbaum, P.C. (Shaaker Bhuiyan of counsel), for appellant. Gary Tsirelman, P.C. (Darya Klein of counsel), for respondent.
Appeal from an order of the Civil Court of the City of New York, Kings County (Robin Kelly Sheares, J.), entered February 8, 2019. The order, insofar as appealed from and as limited by the brief, granted plaintiff’s motion to compel discovery, denied defendant’s cross motion for summary judgment dismissing the complaint, and made implicit CPLR 3212 (g) findings in plaintiff’s favor.
ORDERED that the order, insofar as appealed from, is modified by providing that the branches of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon claims seeking to recover the sums of $325.99, $93.14, $46.57, and $46.57 are granted; as so modified, the order is affirmed, without costs.
In this action by a provider to recover assigned first-party no-fault benefits, plaintiff moved to compel discovery. Defendant cross-moved for summary judgment dismissing the complaint on the grounds that plaintiff’s assignor had failed to appear for duly scheduled independent medical examinations (IMEs), that defendant had never received one of the claims at issue, and that the unpaid portion of the $380.73 claim for services rendered for June 1, 2016 through June 13, 2016 exceeded the amount permitted by the workers’ compensation fee schedule. By order entered February 8, 2019, the Civil Court, insofar as is relevant to this appeal, granted plaintiff’s motion to compel discovery, and denied defendant’s cross motion, but found, in effect pursuant to CPLR 3212 (g), that plaintiff and defendant had established timely mailing of the claim forms and the denial of claim forms.
In support of its cross motion, defendant submitted an affidavit by a supervisor employed by Omnimed Evaluation Services, which had been retained by defendant to schedule IMEs, which affidavit sufficiently established that the IME scheduling letters had been timely and properly mailed (see St. Vincent’s Hosp. of Richmond v Government Empls. Ins. Co., 50 AD3d 1123 [2008]). Defendant also established that plaintiff’s assignor had failed to appear for the duly scheduled IMEs (see Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co., 35 AD3d 720 [2006]). Thus, defendant demonstrated that plaintiff had failed to comply with a condition precedent to coverage (id. at 722). In view of the foregoing, and as plaintiff has not challenged the Civil Court’s finding, in effect, that defendant is otherwise entitled to judgment, the branch of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon claims for the sums of $93.14, $46.57, and $46.57 on the ground that plaintiff’s assignor had failed to appear for duly scheduled IMEs should have been granted.
The affidavit of defendant’s claims representative established that defendant had never received the claim seeking to recover the sum of $325.99 from plaintiff. As plaintiff never established that the claim was mailed to defendant, the branch of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon this claim should have been granted (see Bright Med. Supply Co. v Tri State Consumer Ins. Co., 40 Misc 3d 130[A], 2013 NY Slip Op 51122[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2013]; Vista Surgical Supplies Inc. v Allstate Ins. Co., 14 Misc 3d 129[A], 2006 NY Slip Op 52520[U] [App Term, 2d Dept, 2d & 11th Jud Dists 2006]).
Contrary to defendant’s contention, defendant was not entitled to the dismissal of so much of the complaint as sought to recover upon the unpaid portion of the $380.73 claim for services rendered June 1, 2016 through June 13, 2016 because defendant failed to conclusively establish its defense that the fees charged exceeded the amounts set forth in the workers’ compensation fee schedule (see Rogy Med., P.C. v Mercury Cas. Co., 23 Misc 3d 132[A], 2009 NY Slip Op 50732[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2009]). Indeed, “the fee schedule does not, in and of itself, establish that defendant properly utilized the codes set forth within the workers’ compensation fee schedule to calculate the amount which plaintiff was entitled to recover for each service rendered (see Kingsbrook Jewish Med. Ctr. v Allstate Ins. Co., 61 AD3d 13 [2009]; Rogy Med., P.C. v Mercury Cas. Co., 23 Misc 3d 132[A], 2009 NY Slip Op 50732[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2009])” (Acupuncture Healthcare Plaza I, P.C. v Metlife Auto & Home, 54 Misc 3d 142[A], 2017 NY Slip Op 50207[U], *1-2 [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2017]).
As defendant did not oppose plaintiff’s motion to compel discovery, to the extent that the order compels defendant to respond to plaintiff’s discovery demands pertaining to the unpaid portion of the $380.73 claim for services rendered June 1, 2016 through June 13, 2016, there is no basis to disturb that portion of the order.
Accordingly, the order, insofar as appealed from, is modified by providing that the branches of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover upon claims seeking to recover the sums of $325.99, $93.14, $46.57, and $46.57 are granted.
ALIOTTA, P.J., TOUSSAINT and GOLIA, JJ., concur.
ENTER:
Paul Kenny
Chief Clerk
Decision Date: May 14, 2021
Legal questions (3)
Questions of no-fault law this decision rules on, from our Legal Questions pages. Bars count the decisions on the question by year and court, coloured by category; circles are this decision and the decisions on the question it cites or that cite it. Point at a bar or circle for details. The categories and summaries are Beynenson Law’s classification, made by a language model and checked by a second reading.
Did a party’s evidence establish that it mailed a no-fault claim, denial, verification request or examination notice?
This decision: Different mailing results for different documents or claims in one decision
Held the IME vendor's affidavit established timely mailing of the scheduling letters, but the provider never established mailing of one claim the insurer showed it never received.
Of the 1,384 decisions on this question in the Second Department courts and the Court of Appeals, 55 (this one included) are in the same category.
Did the insurer prove its IME/EUO no-show defense: mailed, compliant scheduling requests and the claimant’s nonappearance?
This decision: Insurer proved mailed, compliant requests and the nonappearance; claimant's answers rejected
Held the insurer proved its IME no-show defense through a scheduling vendor supervisor's affidavit of timely mailing and proof that the assignor failed to appear.
Of the 851 decisions on this question in the Second Department courts and the Court of Appeals, 525 (this one included) are in the same category.
Did the insurer prove that the amount billed exceeded the applicable workers’ compensation fee schedule?
This decision: Insurer's proof did not establish the excess as a matter of law; question left for trial
Held the insurer failed to conclusively establish that the unpaid portion of the claim exceeded the fee schedule, since the schedule alone does not show the codes were properly applied.
Of the 284 decisions on this question in the Second Department courts and the Court of Appeals, 85 (this one included) are in the same category.
Cited in this decision
A label shows how this decision treated the case it cites.
- St. Vincent’s Hosp. of Richmond v Government Empls. Ins. Co. (2008 NY Slip Op 04072) FollowedThe insurer raised factual issues concerning a proper timely denial and its entitlement to deny the hospital's claim.
- Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co. (2006 NY Slip Op 09604) FollowedAn insurer may deny benefits retroactively to the date of loss for failure to attend reasonably required IMEs under 11 NYCRR 65-1.1.
- Bright Med. Supply Co. v Tri State Consumer Ins. Co. (2013 NY Slip Op 51122(U)) FollowedThe insurer established nonreceipt of the provider's claim, and the provider failed to show proper mailing to the insurer's address.
- Vista Surgical Supplies Inc. v Allstate Ins. Co. (2006 NY Slip Op 52520(U)) FollowedThe provider failed to prove mailing of its claim, while the insurer established that it had never received the claim.
- Rogy Med., P.C. v Mercury Cas. Co. (2009 NY Slip Op 50732(U)) FollowedThe insurer's peer review report was not competent evidence, and its fee-schedule proof was insufficient.
- Kingsbrook Jewish Med. Ctr. v Allstate Ins. Co. (2009 NY Slip Op 00351)Judicially noticed diagnosis codes alone do not establish that treatment was wholly unrelated to an insured automobile accident.
Cited by
- Sutphin Complete Med. Care, P.C. v Tri-State Consumer Ins. Co. (2022 NY Slip Op 50586(U))The insurer failed to prove proper IME scheduling notices or the assignor's nonappearances, and its alternative fee-schedule defense also failed.
Similar decisions
- Compas Med., P.C. v GEICO Ins. Co. (2014 NY Slip Op 51857(U))The insurer proved lack of medical necessity for one claim but failed to establish its payment, late-submission and fee-schedule defenses.
- Rockland Family Med. Care, P.C. v State Farm Mut. Auto. Ins. Co. (2022 NY Slip Op 50766(U))The insurer's own affidavits established the provider's entitlement to $97.14 on a fully denied claim billed under CPT code 99205.
- S.O.V. Acupuncture, P.C. v Global Liberty Ins. Co. of N.Y. (2020 NY Slip Op 51004(U))The insurer obtained partial summary judgment on IME nonappearance, late claim submission, and fee schedule grounds.
- Logic Chiropractic, P.C. v Hereford Ins. Co. (2017 NY Slip Op 51754(U))The assignor's conflicting addresses prevented a finding under CPLR 3212 (g) that IME scheduling letters were properly mailed.
- Acupuncture Healthcare Plaza I, P.C. v 21st Century Advantage Ins. Co. (2017 NY Slip Op 50945(U))The insurer failed to prove timely fee-schedule denials or lack of coverage for two claims, but raised a triable coverage issue.