April 13, 2005
A.B. Med. Servs. PLLC v Electric Ins. Co. (2005 NYSlipOp 50542(U))
https://www.beynensonlaw.com/case-law/a-b-med-servs-pllc-v-electric-ins-co-2005-nyslipop-50542u/
- Decided
- April 13, 2005
- Citation
- 2005 NY Slip Op 50542(U)
- Posture
- Summary judgment
- Outcome
- Split result
- Later treatment
- Followed in 2 later decisions (see Cited by)
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 A.B. Med. Servs. PLLC v Electric Ins. Co. (2005 NYSlipOp 50542(U))
| A.B. Med. Servs. PLLC v Electric Ins. Co. |
| 2005 NYSlipOp 50542(U) |
| Decided on April 13, 2005 |
| Appellate Term, Second Department |
| Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431. |
| This opinion is uncorrected and will not be published in the printed Official Reports. |
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE TERM: 2nd and 11th JUDICIAL DISTRICTS
PRESENT: April 13, 2005 SUPREME COURT OF THE STATE OF NEW YORK APPELLATE TERM : 2nd and 11th JUDICIAL DISTRICTS PRESENT : PESCE, P.J., RIOS and BELEN, JJ.
2004-860 K C
against
Electric Insurance Company, Respondent.
Appeal by plaintiffs, as limited by their brief on appeal, from so much of an order of the Civil Court, Kings County (E. Prus, J.), entered on April 20, 2004, as denied their motion for summary judgment.
Order unanimously modified by granting the motion for summary judgment by plaintiff Daniel Kim’s Acupuncture P.C. in the sum of $3,475.56 and matter remanded to the court below for the calculation of statutory interest and an assessment of attorney’s fees thereon, and for all further proceedings on the remaining claims; as so modified, affirmed without costs.
In this action to recover assigned first-party no-fault benefits, plaintiffs moved for summary judgment in the sum of $11,139.79. We note at the outset that in their brief on appeal, plaintiffs have effectively withdrawn the claim of plaintiff Square Synagogue Transportation Inc. in the sum of $425. Moreover, said plaintiff’s motion for summary judgment as to its claim for $100, which defendant denied receiving, was properly denied since plaintiff’s proof of mailing as to this claim indicates a post date which is prior to the date of the bill. In the absence of any explanation of the discrepancy, plaintiff’s proof is insufficient to establish prima facie entitlement to summary judgment as to this claim. [*2]
With regard to the remaining claims, plaintiffs established a prima facie entitlement to summary judgment by proof that they submitted the claims, setting forth the fact and the amount of the loss sustained, and that payment of no-fault benefits was overdue (see Insurance Law § 5106 [a]; Mary Immaculate Hosp. v Allstate Ins. Co., 5 AD3d 742 [2004]; A.B. Med. Servs. PLLC v Lumbermens Mut. Cas. Co., 4 Misc 3d 86 [App Term, 2d & 11th Jud Dists 2004]; Amaze Med. Supply v Eagle Ins. Co., 2 Misc 3d 128[A], 2003 NY Slip Op 51701[U] [App Term, 2d & 11th Jud Dists]).
In opposition to plaintiffs’ motion, defendant argued that the claims of A.B. Medical Services PLLC, D.A.V. Chiropractic P.C., Daniel Kim’s Acupuncture P.C. and Square Synagogue Transportation Inc., in the sum of $7,139.23, were properly denied on the ground that plaintiffs’ assignor failed to attend scheduled independent medical examinations (IMEs).
Where “an insurer timely asserts in its claim denial form an injured person’s failure to comply with a reasonable and proper pre-claim IME request, and establishes such failure in admissible form in opposition to a plaintiff’s motion for summary judgment, the presumption of medical necessity which attaches to the claim form is rebutted . . . and such proof defeats the motion” (Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co., ___Misc 3d ___, 2004 NY Slip Op 24527 [App Term, 2d & 11th Jud Dists]; see also S&M Supply Inc. v Peerless Ins. Co., 6 Misc 3d 127[A], 2004 NY Slip Op 51683[U] [App Term, 2d & 11th Jud Dists]).
It is undisputed that defendant issued timely denials based on the nonattendance of plaintiffs’ assignor at pre-claim IMEs scheduled by defendant. Contrary to plaintiffs’ contention, the letter of Transcion Medical P.C., which schedules IMEs for defendant, and defendant’s denial of claim forms, which were submitted as part of plaintiffs’ moving papers, indicated that plaintiffs’ assignor did not appear for all of the scheduled IMEs listed in Transcion’s letter. Under the circumstances presented, in our opinion, such selective attendance by plaintiffs’ assignor established the assignors’ receipt of all IME requests listed in said letter. In the absence of any reasonable excuse for the nonappearance by plaintiffs’ assignor, defendant effectively rebutted the presumption of medical necessity which ordinarily attaches to the claim forms. This is so, even though it is uncontroverted that plaintiffs’ assignor attended some of the IMEs. Therefore, its defense of lack of medical necessity of the services provided to plaintiffs’ assignor was still viable and raised a triable issue with respect thereto. Accordingly, the court below properly denied said plaintiffs’ motion for summary judgment in the sum of $7,139.23 (see Stephen Fogel Psychological, P.C. v Progressive Casualty Ins. Co., Misc 3d , 2004 NY Slip Op 24527, supra).
With regard to the additional claims of Daniel Kim’s Acupuncture P.C. in the amount of $3,475.55, which were timely denied, the stated basis for denial was lack of medical necessity, rather than the failure to appear for an IME. In opposition to the motion for summary judgment, defendant was required to submit proof in admissible form to rebut plaintiff’s prima facie showing (A.B. Med. Servs. PLLC v Lumbermens Mut. Cas. Co., 4 Misc 3d 86, supra). Defendant submitted an unsworn peer review report of an acupuncturist. Since said report was not in admissible form, it was insufficient to warrant denial of said plaintiff’s motion for summary judgment (see CPLR 2106; Alvarez v Prospect Hosp., 68 NY2d 320, 324 [1986]; A.B. Med. Servs. PLLC v Lumbermens Mut. Cas. Co., 4 Misc 3d 86, supra; A.B. Med. Servs. v New York Cent. Mut. Fire Ins. Co., 3 Misc 3d 136[A], 2004 NY Slip Op 50507[U] [App Term, 2d & [*3]11th Jud Dists]).
We note that to the extent that the decision of the court below rests on the lack of authentication of the assignments, it is erroneous. The lack of authentication of an assignor’s signature, in and of itself, does not constitute a defect in the absence of any statutory and regulatory requirement for the same (A.B. Med. Servs. PLLC v Nationwide Mut. Ins. Co., 6 Misc 3d 70 [App Term, 2d & 11th Jud Dists 2004]). Even assuming arguendo that a lack of authentication constitutes a cognizable defect, defendant’s failure to seek verification of the assignments and to allege any deficiency in the assignments in its denial of claim forms constitutes a waiver of any defenses with respect thereto (see id; see also New York Hosp. Med. Ctr. of Queens v New York Cent. Mut. Fire Ins. Co., 8 AD3d 640 [2004]; Presbyterian Hosp. in City of N. Y. v Aetna Cas. & Sur. Co., 233 AD2d 433 [1996]; Park Health Ctr. v Eveready Ins. Co., 2001 NY Slip Op 40665[U] [App Term, 2d & 11th Jud Dists]).
Accordingly, the order of the court below is modified by granting the motion for summary judgment by plaintiff Daniel Kim’s Acupuncture P.C. in the sum of $3,475.56, and remanding the matter for the calculation of statutory interest and an assessment of attorney’s fees thereon pursuant to Insurance Law § 5106 (a) and the regulations promulgated thereunder, and for all further proceedings on the remaining claims.
Decision Date: April 13, 2005
Legal questions (5)
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.
On summary judgment or another pretrial motion, what must a no-fault claimant show to establish its prima facie case?
This decision: Claimant's proof held to make out its prima facie case
Held the providers established their prima facie case by proof of submitting claims stating the fact and amount of loss and that payment was overdue, except one $100 claim whose proof of mailing bore a post date earlier than the bill.
Of the 1,065 decisions on this question in the Second Department courts and the Court of Appeals, 513 (this one included) are in the same category.
Did a party’s evidence establish that it mailed a no-fault claim, denial, verification request or examination notice?
This decision: The provider's or claimant's proof did not establish mailing of its claim form, NF-2 or verification response
Held one provider's proof of mailing a $100 claim insufficient because it showed a post date before the bill's date and the discrepancy was unexplained, so no prima facie showing for that claim.
Of the 1,400 decisions on this question in the Second Department courts and the Court of Appeals, 67 (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 that the assignor's selective attendance showed he received all the scheduled IME requests and that his unexcused nonappearance, shown by the scheduler's letter and the denials, sufficed to defeat the providers' summary judgment motion.
Of the 858 decisions on this question in the Second Department courts and the Court of Appeals, 527 (this one included) are in the same category.
Did the insurer’s proof establish lack of medical necessity, and did the provider’s evidence rebut it?
This decision: Insurer's medical-necessity proof failed (conclusory, no factual basis or rationale, inadmissible, not credited)
Held the insurer's unsworn acupuncturist peer review report inadmissible and therefore insufficient to raise a triable issue on medical necessity, so the provider was granted summary judgment on those claims.
Of the 617 decisions on this question in the Second Department courts and the Court of Appeals, 109 (this one included) are in the same category.
Could the insurer contest the validity of the provider’s assignment of benefits, or had it waived that defense?
This decision: On the merits, the assignment or the claimant's showing is adequate, or the alleged defect is not a defect (rules on the question, but another ground decided the case)
Held the lower court erred to the extent it relied on lack of authentication of the assignments, since no statute or regulation requires authentication, adding that the insurer waived the objection by not seeking verification or stating it in its denials.
Of the 96 decisions on this question in the Second Department courts and the Court of Appeals, 31 (this one included) are in the same category.
Cited in this decision
A label shows how this decision treated the case it cites.
- Mary Immaculate Hosp. v Allstate Ins. Co. (2004 NY Slip Op 02359)The hospitals established entitlement to summary judgment by proving that statutory billing forms were mailed and received and payment was overdue.
- A.B. Med. Servs. PLLC v Lumbermens Mut. Cas. Co. (2004 NY Slip Op 24194) FollowedAn insurer's timely medical-necessity denial does not replace admissible proof opposing a provider's summary judgment motion.
- Amaze Med. Supply v Eagle Ins. Co. (2003 NY Slip Op 51701(U))A provider's completed claim forms establish its prima facie case without additional medical proof when the insurer is precluded.
- Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co. (2004 NY Slip Op 24527) FollowedA proven failure to attend a reasonably requested preclaim IME, timely raised in a denial, does not alone warrant dismissal.
- S&M Supply Inc. v Peerless Ins. Co. (2004 NY Slip Op 51683(U))A proven, unexcused failure to attend a reasonable preclaim IME rebuts the claim forms' presumption of medical necessity.
- A.B. Med. Servs. v N. Y. Cent. Mut. Fire Ins. Co. (2004 NY Slip Op 50507(U))An insurer opposing summary judgment on medical necessity must submit admissible proof even if unaffirmed reports supported a timely denial.
- A.B. Med. Servs. PLLC v Nationwide Mut. Ins. Co. (2004 NY Slip Op 24506) FollowedThe providers' billing manager affidavit failed to establish submission of properly completed claim forms.
- New York Hosp. Med. Ctr. of Queens v New York Cent. Mut. Fire Ins. Co. (2004 NY Slip Op 05626)The insurer failed to establish mailing of assignment-verification requests and could not defeat the hospitals' summary judgment motion.
Cited by
A label shows how the later decision treated this one.
- Lexington Acupuncture, P.C. v State Farm Ins. Co. (2006 NY Slip Op 26251) FollowedThe provider's summary judgment motion was premature because discovery could establish fraudulent incorporation and reimbursement ineligibility.
- S & M Supply Inc. v State-Wide Ins. Co. (2005 NYSlipOp 51046(U)) FollowedA provider's billing manager need not have personal knowledge that prescribed equipment was delivered to establish a prima facie case.
- Delta Diagnostic Radiology, P.C. v Farmers New Century Ins. Co. (2007 NY Slip Op 52284(U))The insurer failed to prove timely mailing of its denials and was precluded from asserting medical-necessity and fee-schedule defenses.
Similar decisions
- A.B. Med. Servs. PLLC v American Tr. Ins. Co. (2005 NYSlipOp 51316(U))The insurer failed to prove mailing of IME notices to the assignors, defeating its nonappearance defense to summary judgment.
- A.B. Med. Servs. PLLC v Encompass Ins. (2005 NY Slip Op 51892(U))Transportation benefits are nonassignable under the revised no-fault regulations for claims submitted on or after April 5, 2002.
- A.B. Med. Servs. v State Farm Mut. Auto. Ins. Co. (2004 NY Slip Op 50387(U))The insurer's EUO request did not toll the denial period under the former regulations, and its fraud evidence raised no triable issue.
- D.A.V. Chiropractic P.C. v American Tr. Ins. Co. (2005 NYSlipOp 50609(U))An insurer's timely denial and admissible proof of a reasonable pre-claim IME nonappearance rebut the presumption of medical necessity.
- A.B. Med. Servs. PLLC v Prudential Prop. & Cas. Ins. Co. (2005 NY Slip Op 50076(U))The insurer's affidavit and EUO evidence raised a triable coverage issue despite untimely denials of certain claims.