February 8, 2018
Choice Health Chiropractic, P.C. v American Tr. Ins. Co. (2018 NY Slip Op 50185(U))
https://www.beynensonlaw.com/case-law/choice-health-chiropractic-p-c-v-american-tr-ins-co-2018-ny-slip-op50185u/
- Decided
- February 8, 2018
- Citation
- 2018 NY Slip Op 50185(U) · 58 Misc 3d 155(A)
- Posture
- Summary judgment
- Outcome
- Split result
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 Choice Health Chiropractic, P.C. v American Tr. Ins. Co. (2018 NY Slip Op 50185(U))
| Choice Health Chiropractic, P.C. v American Tr. Ins. Co. |
| 2018 NY Slip Op 50185(U) [58 Misc 3d 155(A)] |
| Decided on February 8, 2018 |
| 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| This opinion is uncorrected and will not be published in the printed Official Reports. |
Decided on February 8, 2018
SUPREME COURT, APPELLATE TERM, SECOND DEPARTMENT, 9th and 10th
JUDICIAL DISTRICTS
PRESENT: : JERRY GARGUILO, J.P., ANTHONY MARANO, TERRY JANE
RUDERMAN, JJ
2016-1038 S C
against
American Transit Insurance Company, Respondent.
The Law Office of Gregory A. Goodman, P.C., (Gregory A. Goodman), for appellant. Law Offices of Daniel J. Tucker, (Daniel J. Tucker, Joshua Goldberg and Netanel BenChaim of counsel), for respondent.
Appeal from an order of the District Court of Suffolk County, Fourth District (James F. Matthews, J.), dated April 19, 2016. The order, insofar as appealed from as limited by the brief, granted defendant’s motion for summary judgment dismissing the complaint and denied plaintiff’s cross motion for summary judgment or, in the alternative, to strike defendant’s answer or compel defendant to produce its no-fault examiner for a deposition.
ORDERED that the order, insofar as appealed from, is modified by providing that the branch of defendant’s motion seeking summary judgment dismissing so much of the complaint as sought to recover upon a claim for $1,310.94 is denied; as so modified, the order is affirmed, without costs.
In this action by a provider to recover assigned first-party no-fault benefits, plaintiff appeals, as limited by its brief, from so much of an order of the District Court as granted defendant’s motion for summary judgment dismissing the complaint and denied plaintiff’s cross motion for summary judgment or, in the alternative, to strike defendant’s answer or compel defendant to produce its no-fault examiner for a deposition.
In support of its motion, defendant established that it had timely mailed letters scheduling an initial and follow-up independent medical examination (IME) (see St. Vincent’s Hosp. of [*2]Richmond v Government Empls. Ins. Co., 50 AD3d 1123 [2008]), and that plaintiff’s assignor had failed to appear for the scheduled IMEs on January 9, 2014 and February 6, 2014 (see Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co., 35 AD3d 720 [2006]). Plaintiff’s claim for $1,019.62 was received on March 17, 2014 and timely denied, based on the assignor’s failure to appear for IMEs, on April 3, 2014 (see St. Vincent’s Hosp. of Richmond, 50 AD3d 1123); therefore, plaintiff has failed to establish a basis to disturb the portion of the order which granted the branch of defendant’s motion seeking summary judgment dismissing so much of the complaint as sought to recover upon that claim.
While defendant did not deny plaintiff’s $1,310.94 claim, which it had received on January 7, 2014, within 30 days of receipt of that claim or of the second IME nonappearance, defendant demonstrated, prima facie, that, upon receipt of that claim, it had timely mailed initial and follow-up requests for written verification (see 11 NYCRR 65-3.5 [b]; 65-3.8 [l]; St. Vincent’s Hosp. of Richmond, 50 AD3d 1123) and that it had timely denied the claim, based on the assignor’s failure to appear for IMEs, within 30 days of receiving the requested verification (see 11 NYCRR 65-3.8 [l]; St. Vincent’s Hosp. of Richmond, 50 AD3d 1123; Alev Med. Supply, Inc. v New York Cent. Mut. Fire Ins. Co., 38 Misc 3d 143[A], 2013 NY Slip Op 50258[U] [App Term, 2d Dept, 2d, 11th & 13th Jud Dists 2013]). However, as the affidavit submitted by plaintiff was sufficient to demonstrate the existence of an issue of fact regarding defendant’s mailing of its initial and follow-up requests for written verification, there is an issue of fact as to whether defendant’s time to pay or deny that claim was tolled by virtue of the pending verification requests and, thus, whether defendant’s denial of plaintiff’s $1,310.94 claim was timely. In light of the foregoing, plaintiff’s contention that the branch of its cross motion seeking summary judgment should have been granted lacks merit.
To the extent plaintiff asserts that the District Court should have granted the branches of plaintiff’s cross motion seeking to strike defendant’s answer or, in the alternative, compel defendant to produce its no-fault examiner for a deposition, plaintiff failed to demonstrate that it had requested a deposition in this action, as the affidavit of service for the deposition notice annexed to plaintiff’s cross motion is for a different case. Consequently, these branches of plaintiff’s cross motion were properly denied.
Accordingly, the order, insofar as appealed from, is modified by providing that the branch of defendant’s motion seeking summary judgment dismissing so much of the complaint as sought to recover upon the $1,310.94 claim is denied.
GARGUILO, J.P., MARANO and RUDERMAN, JJ., concur.
ENTER:
Paul Kenny
Chief Clerk
Decision Date: February 08, 2018
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.
Is an IME/EUO no-show defense precluded if the insurer did not timely deny the claim on that ground?
This decision: No-show defense is subject to preclusion and fails for want of a timely, proper denial
Upheld dismissal of one claim timely denied on the IME no-show ground, but denied summary judgment on another because an issue of fact on verification tolling left the denial's timeliness unestablished.
Of the 508 decisions on this question in the Second Department courts and the Court of Appeals, 166 (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: Different mailing results for different documents or claims in one decision
Found the IME letters and denials proved mailed, but held the provider's affidavit raised an issue of fact on the mailing of the verification requests, which decided one claim.
Of the 1,400 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 (rules on the question, but another ground decided the case)
Held the insurer established timely mailed initial and follow-up IME letters and the assignor's failure to appear for both IMEs.
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.
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.
- Alev Med. Supply, Inc. v New York Cent. Mut. Fire Ins. Co. (2013 NY Slip Op 50258(U))The insurer's IME nonappearance denials were timely because it issued them within 30 days after receiving requested written verification.
Cited by
- Longevity Med. Supply, Inc. v Progressive Ins. Co. (2020 NY Slip Op 20137)Timely IME no-show denials defeated the provider's motion where it did not show that the denials were legally insufficient.
- New Chiropractic Care, P.C. v Nationwide Ins. Co. of N.Y. (2020 NY Slip Op 50652(U))A provider may not dictate an EUO location when the insurer designates a reasonably convenient place under 11 NYCRR 65-3.5 (e).
Similar decisions
- 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.
- Clinton Place Med., P.C. v New York Cent. Mut. Fire Ins. Co. (2014 NY Slip Op 50963(U))The insurer proved its IME nonappearance defense for 13 claims but failed to establish timely denial of the fourteenth.
- Progressive Health Chiropractic, P.C. v American Tr. Ins. Co. (2017 NY Slip Op 50603(U))The insurer failed to prove two IME nonappearances on one claim, and conflicting mailing evidence precluded summary judgment on another.
- J.C. Healing Touch Rehab, P.C. v American Tr. Ins. Co. (2016 NY Slip Op 50033(U))The provider's verification-mailing proof raised a factual issue on prematurity, but its own summary judgment proof was deficient.
- Compas Med., P.C. v American Tr. Ins. Co. (2017 NY Slip Op 51239(U))The provider's mailing affidavit raised a factual issue over receipt of verification, and the insurer failed to prove fee-schedule payment.