September 20, 2005
Careplus Med. Supply Inc. v Allstate Ins. Co. (2005 NYSlipOp 51526(U))
https://www.beynensonlaw.com/case-law/careplus-med-supply-inc-v-allstate-ins-co-2005-nyslipop-51526u/
- Decided
- September 20, 2005
- Citation
- 2005 NY Slip Op 51526(U)
- Posture
- Summary judgment
- Outcome
- Provider prevailed
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 Careplus Med. Supply Inc. v Allstate Ins. Co. (2005 NYSlipOp 51526(U))
| Careplus Med. Supply Inc. v Allstate Ins. Co. |
| 2005 NYSlipOp 51526(U) |
| Decided on September 20, 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| This opinion is uncorrected and will not be published in the printed Official Reports.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: PATTERSON, J.P., RIOS and BELEN, JJ.
2004-1619 K C
against
Allstate Insurance Company, Respondent.
Appeal from an order of the Civil Court of the City of New York, Kings County (Manuel J. Mendez, J.), entered September 28, 2004. The order denied plaintiff’s motion for summary judgment.
Order unanimously reversed without costs, plaintiff’s motion for summary judgment granted and matter remanded to the court below for a calculation of statutory interest and an assessment of attorney’s fees.
In this action to recover first-party no-fault benefits for medical equipment furnished to its assignors, plaintiff established its entitlement to summary judgment by its proof that it submitted the functional equivalent of the statutory claim forms (11
NYCRR 65-3.5 [a], [f]), setting forth the fact and amounts of the losses 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]). Defendant’s failure to pay or deny [*2]assignor Figueroa’s claim for $580 and assignor Rivera’s claims for $840 and $1,085 within the statutory 30-day claim determination period (11 NYCRR 65-3.8 [c]), or to prove a tolling of said period precluded the defenses set forth in the claim denial forms (Presbyterian Hosp. in City of N.Y. v Maryland Cas. Co., 90 NY2d 274, 282 [1997]; Triboro Chiropractic & Acupuncture PLLC v New York Cent. Mut. Fire Ins. Co., 7 Misc 3d 138[A], 2005 NY Slip Op 50856[U] [App Term, 2d & 11th Jud Dists]).
As for the defenses that survive the preclusion sanction, i.e., the alleged absence of an applicable policy and assignors’ fraudulent conduct with respect to the underlying traffic incidents (Matter of Metro Med. Diagnostics v Eagle Ins. Co., 293 AD2d 751 [2002]; Mount Sinai Hosp. v Triboro Coach, 263 AD2d 11, 18-19 [1999]), defendant failed to establish that triable issues exist as to either defense. Defendant’s claim that plaintiff did not prove that its assignors are covered by a policy issued by defendant is without merit as plaintiff’s claim forms established the matter prima facie and defendant offered no proof to the contrary. Further, absent proof sufficient to create a triable issue as to whether any of the traffic accidents were staged with the intent to defraud, defendant failed to prove that the defense was based on “a founded belief that the alleged injur[ies] do[] not arise out of an insured incident” (Central Gen. Hosp. v Chubb Group of Ins. Cos., 90 NY2d 195, 199 [1997]).
Defendant based its partial denials of most of the remaining claims on the improper ground that the sums sought for the items of medical equipment exceeded an alleged average of suppliers’ prevailing rates in plaintiff’s geographic location. The insurance regulations governing medical equipment and supplies applicable to the instant action limit a provider’s recovery of medical equipment benefits to 150 percent of cost (11 NYCRR Appendix 17-C, part E [b] [1]). This “applicable fee schedule” constitutes the only limitation on recovery and a defendant’s denial of benefits on the ground that the fees sought exceeded prevailing rates for such equipment in the provider’s geographical location has been rejected as without merit (Amaze Med. Supply v Allstate Ins. Co., 3 Misc 3d 43, 44 [App Term, 2d & 11th Jud Dists 2004]; King’s Med. Supply v Allstate Ins. Co., 2 Misc 3d 127[A], 2003 NY Slip Op 51681[U] [App Term, 9th & 10th Jud Dists]). It is noted that pursuant to the revised Insurance Department regulations regarding durable medical equipment and supplies, effective October 6, 2004 (see Circular Letter No. 8 [2004]; 11 NYCRR Appendix 17-C, part F, eff. October 6, 2004), the current fee schedule for medical equipment sets forth, as an alternative to the 150 percent limit, whichever is less, the “usual and customary price charged to the general public” (11 NYCRR Appendix 17-C, part F [a] [2]).
As to the defense based on defective assignments, defendant’s failure to seek verification of the assignments or to allege any deficiency in the assignments in its claim denial forms “constitutes a waiver of any defenses with respect [to them]” (Ocean Diagnostic Imaging P.C. v Travelers Prop. Cas. Corp., 7 Misc 3d 137[A], 2005 NY Slip Op 50790[U] [App Term, 2d & 11th Jud Dists]; see also New York Hosp. Med. Ctr. of Queens v New York Cent. Mut. Fire Ins. Co., 8 AD3d 640 [2004]; Capio Med., P.C. v Progressive Cas. Ins. Co., 7 Misc 3d 129[A], 2005 NY Slip Op 50526[U] [App Term, 2d & 11th Jud Dists]). Defendant’s further claim that plaintiff cannot establish a prima facie case for the delivery of equipment to the assignors because its manager-affiant did not personally supply the equipment or witness the equipments’ “turnover” is also without merit. The affidavit of plaintiff’s officer and billing manager sufficiently “[s]et forth [*3][his] duties so as to support the conclusion that the attached exhibits were sufficiently accurate and trustworthy to merit their admission into evidence pursuant to the business record exception to the hearsay rule (see CPLR 4518 [a]; People v Kennedy, 68 NY2d 569 [1986]), and said exhibits established that the supplies were furnished to the assignor” (King’s Med. Supply, Inc. v Hereford Ins. Co., 5 Misc 3d 55, 56 [App Term, 9th & 10th Jud Dists 2004]; see also Ocean Diagnostic Imaging P.C. v State Farm Mut. Auto. Ins. Co., 4 Misc 3d 141[A], 2004 NY Slip Op 51032[U] [App Term, 9th & 10th Jud Dists]).
We have considered the remaining defenses and find them to be similarly without merit (see Nyack Hosp. v Metropolitan Prop. & Cas. Ins. Co., 16 AD3d 564, 565 [2005]; New York Hosp. Med. Ctr. of Queens v New York Cent. Mut. Fire Ins. Co., 8 AD3d 640, supra; Careplus Med. Supply Inc. v Travelers Home and Mar. Ins. Co., 7 Misc 3d 133[A], 2005 NY Slip Op 50648[U] [App Term, 2d & 11th Jud Dists]).
Accordingly, plaintiff’s motion for summary judgment is granted and the matter remanded to the court below for a calculation of statutory interest and an assessment of attorney’s fees pursuant to Insurance Law § 5106 (a) and the regulations promulgated thereunder.
Decision Date: September 20, 2005
Legal questions (4)
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 the insurer prove that the amount billed exceeded the applicable workers’ compensation fee schedule?
This decision: Court finally rejected the fee schedule defense; provider recovers the disputed amount
Rejected as improper the insurer's partial denials based on suppliers' prevailing geographic rates, holding the 150%-of-cost limit was the only applicable fee schedule limitation, and granted the supplier summary judgment.
Of the 285 decisions on this question in the Second Department courts and the Court of Appeals, 29 (this one included) are in the same category.
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 (rules on the question, but another ground decided the case)
Held the supplier established its prima facie case through claim forms showing the fact and amount of loss and overdue payment, rejecting arguments that coverage was unproven and that its billing manager lacked personal knowledge of delivery.
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 the insurer show the claimed injuries did not arise from a covered accident (staged, intentional, or unrelated)?
This decision: Insurer's proof did not raise an issue or failed at trial; provider prevails on it (rules on the question, but another ground decided the case)
Held the insurer offered no proof creating a triable issue that any of the accidents were staged with intent to defraud, so it failed to show a founded belief that the injuries did not arise from an insured incident.
Of the 234 decisions on this question in the Second Department courts and the Court of Appeals, 80 (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: Insurer barred from contesting the assignment because it did not timely object, verify, deny or plead on that ground (rules on the question, but another ground decided the case)
Held the insurer waived its defective-assignment defense by failing to seek verification of the assignments or to state any deficiency in them in its claim denial forms.
Of the 96 decisions on this question in the Second Department courts and the Court of Appeals, 48 (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)An insurer's timely medical-necessity denial does not replace admissible proof opposing a provider's summary judgment motion.
- Triboro Chiropractic & Acupuncture P.L.L.C. v New York Cent. Mut. Fire Ins. Co. (2005 NYSlipOp 50856(U))The provider obtained partial summary judgment on three untimely denied claims; timely fee schedule denials raised triable issues on the rest.
- Amaze Med. Supply v Allstate Ins. Co. (2004 NY Slip Op 24119) FollowedAn insurer may not deny equipment fees as exceeding local prevailing rates when the applicable schedule limits reimbursement to 150% of cost.
- King’S Med. Supply v Allstate Ins. Co. (2003 NY Slip Op 51681(U)) FollowedMedical equipment reimbursement is governed by the 150-percent-of-cost fee schedule rather than prevailing local rates.
- Ocean Diagnostic Imaging P.C. v Travelers Prop. Cas. Corp. (2005 NY Slip Op 50790(U)) FollowedThe insurer's affidavits raised a factual issue whether the claimed injuries arose from an insured incident.
- 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.
- Capio Med., P.C. v Progressive Cas. Ins. Co. (2005 NYSlipOp 50526(U))The insurer's EUO requests did not toll the denial period because it failed to prove an authorizing endorsement or timely requests.
- King’s Med. Supply, Inc. v Hereford Ins. Co. (2004 NY Slip Op 24343) FollowedThe insurer's mailing affidavit raised a triable issue whether its denial was timely, defeating the provider's summary judgment motion.
- Ocean Diagnostic Imaging P.C. v State Farm Mut. Auto. Ins. Co. (2004 NY Slip Op 51032(U))The insurer's investigator raised a triable staged-collision coverage issue despite the provider's adequate billing proof.
- Nyack Hosp. v Metropolitan Prop. & Cas. Ins. Co. (2005 NY Slip Op 02235)The insurer failed to prove mailing of its denial, and the denial was incomplete even if timely.
- Careplus Med. Supply Inc. v Travelers Home & Mar. Ins. Co. (2005 NYSlipOp 50648(U))The insurer failed to establish verification tolling because requests were untimely or unproved and its policy's EUO endorsement was not shown.
Similar decisions
- Careplus Med. Supply, Inc v Allstate Indem. Co. (2005 NY Slip Op 51527(U))The insurer improperly reduced equipment claims to local prevailing rates under a fee schedule allowing 150 percent of cost.
- Careplus Med. Supply Inc. v State-Wide Ins. Co. (2005 NY Slip Op 25545)The insurer's completed denial form established receipt of the provider's claims and showed that the denial was untimely.
- S & M Supply Inc. v State-Wide Ins. Co. (2005 NYSlipOp 51046(U))A provider's billing manager need not have personal knowledge that prescribed equipment was delivered to establish a prima facie case.
- S&M Supply Inc. v Progressive Ins. Co. (2005 NYSlipOp 51312(U))The insurer's excessive-charge defenses failed because one denial was untimely and the other lacked admissible proof or a valid regulatory basis.
- Careplus Med. Supply Inc. v General Assur. Co. (2005 NY Slip Op 50429(U))The insurer failed to prove mailing of preclaim IME notices to the assignors and was precluded from asserting nonattendance on one late-denied claim.