April 22, 2005
D.A.V. Chiropractic P.C. v American Tr. Ins. Co. (2005 NYSlipOp 50609(U))
https://www.beynensonlaw.com/case-law/d-a-v-chiropractic-p-c-v-american-tr-ins-co-2005-nyslipop-50609u/
- Decided
- April 22, 2005
- Citation
- 2005 NY Slip Op 50609(U)
- Posture
- Summary judgment
- Outcome
- Insurer prevailed
- Later treatment
- Followed in 4 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 D.A.V. Chiropractic P.C. v American Tr. Ins. Co. (2005 NYSlipOp 50609(U))
| D.A.V. Chiropractic P.C. v American Tr. Ins. Co. |
| 2005 NYSlipOp 50609(U) |
| Decided on April 22, 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| This opinion is uncorrected and will not be published in the printed Official Reports.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., GOLIA and RIOS, JJ.
2004-595 K C NO. 2004-595 K C
against
American Transit Insurance Company, Respondent.
Appeal by plaintiffs from so much of an order of the Civil Court, Kings County (E. Prus, J.), entered on February 17, 2004, as denied the motion for summary judgment by plaintiff D.A.V. Chiropractic P.C., as assignee of Latoya Jones, seeking the sum of $2,712.08.
Order, insofar as appealed from by plaintiff D.A.V. Chiropractic P.C., affirmed without costs.
Appeal, insofar as taken by plaintiff Daniel Kim’s Acupuncture P.C., dismissed.
In this action to recover assigned first-party no-fault benefits, plaintiff D.A.V. Chiropractic P.C., established a prima facie entitlement to summary judgment in the sum of $2,712.08 for medical services rendered to its assignor, Latoya Jones, by proof that it submitted 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 plaintiff’s motion and [*2]in support of its cross motion for summary judgment, defendant argued that the claims were properly denied based on the assignor’s failure to attend 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 plaintiff’s assignors at the pre-claim IMEs scheduled by defendant. Defendant’s proof of mailing, consisting of the affidavit of the operations manager for Independent Physical Exam Referrals, which schedules IMEs for defendant, and the affidavit of defendant’s claims representative, was sufficient to demonstrate that defendant followed a standard office practice or procedure designed to ensure that items are properly addressed and mailed (see Residential Holding Corp. v Scottsdale Ins. Co., 286 AD2d 679, 680 [2001]; Amaze Med. Supply Inc. v New York Cent. Mut. Ins. Co., 6 Misc 3d 126[A], 2004 NY Slip Op 51680[U] [App Term, 2d & 11th Jud Dists]; cf. Hospital for Joint Diseases v Nationwide Mut. Ins. Co., 284 AD2d 374 [2001]; Contemp. Med. Diag. & Treatment, P.C. v Government Employees Ins. Co., Misc 3d , 2005 NY Slip Op 50254[U] [App Term, 2d & 11th Jud Dists]).
Accordingly, defendant effectively rebutted the presumption of medical necessity which ordinarily attaches to plaintiff’s claim forms, and raised a triable issue of fact as to the medical necessity of the services rendered plaintiff’s assignors (see Stephen Fogel Psychological, P.C. v Progressive Casualty Ins. Co., Misc 3d , 2004 NY Slip Op 24527[U], supra). Inasmuch as plaintiff neither offered a valid excuse for its assignors’ nonappearance nor demonstrated that the IME requests were unreasonable under the circumstances, a triable issue as to medical necessity was raised. Therefore, the court properly denied plaintiff’s motion for summary judgment as well as defendant’s cross motion for summary judgment.
Inasmuch as no issue is raised by the remaining appellant, the appeal with respect to it is dismissed (see Praeger v Praeger, 162 AD2d 671 [1990]).
Patterson, J.P. and Rios, J. concur.
Golia, J., concurs in part and dissents in part in a separate memorandum.
Golia, J., concurs in part and dissents in part and votes to modify the order in the following memorandum:
Although I agree with the findings of my colleagues that defendant’s proof of mailing IME scheduling letters demonstrated that defendant, in conjunction with Independent Physical Exam Referrals, adhered to established business practices of proper mailing (see Residential Holding Corp. v Scottsdale Ins. Co., 286 AD2d 679 [2001]), and that plaintiff failed to come forward with an acceptable excuse for its
[*3]
assignors’ nonattendance, it is my opinion that plaintiff’s failure to have done so warrants the granting of defendant’s cross motion for summary judgment and the substantive sanction of dismissal, for the reasons set forth in my dissent in the case of Stephen Fogel Psychological, P.C. v Progressive Cas. Ins. Co. ( Misc 3d , 2004 NY Slip Op 24527 [App Term, 2d & 11th Jud Dists]).
Decision Date: April 22, 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 a party’s evidence establish that it mailed a no-fault claim, denial, verification request or examination notice?
This decision: The insurer's (or its agent's) proof established mailing of its denial, verification request or IME/EUO notice
Held the affidavits of the IME scheduling company's operations manager and the insurer's claims representative showed a standard office practice designed to ensure the IME letters were properly addressed and mailed.
Of the 1,384 decisions on this question in the Second Department courts and the Court of Appeals, 806 (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 mailing of the pre-claim IME letters and the provider offered no excuse for the nonappearance or showing the requests were unreasonable, but under the then rule this only raised a triable issue of medical necessity, so both motions were denied.
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.
Is an IME/EUO no-show defense precluded if the insurer did not timely deny the claim on that ground?
This decision: Timely denial required as part of the no-show defense, and the insurer showed it (rules on the question, but another ground decided the case)
Applied the rule that a pre-claim IME no-show defense must be timely asserted in the denial and noted it was undisputed that the insurer timely denied on that ground.
Of the 500 decisions on this question in the Second Department courts and the Court of Appeals, 334 (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 provider established prima facie entitlement by proof that it submitted claims setting forth the fact and amount of loss and that payment was overdue, though the motion was denied on a triable issue.
Of the 1,063 decisions on this question in the Second Department courts and the Court of Appeals, 511 (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) FollowedThe 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)) FollowedA 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.
- Amaze Med. Supply Inc. v New York Cent. Mut. Ins. Co. (2004 NY Slip Op 51680(U)) FollowedThe assignor's unexcused failure to attend reasonable preclaim IMEs raised a medical-necessity issue requiring denial of both summary judgment motions.
- Contemp. Med. Diag. & Treatment, P.C. v Government Employees Ins. Co. (2005 NY Slip Op 50254(U)) Contrasted (cf., but see)The insurer's conclusory office-practice affidavit failed to prove timely mailing of verification requests.
Cited by
A label shows how the later decision treated this one.
- Amaze Med. Supply Inc. v General Assur. Co. (2006 NY Slip Op 50307(U)) FollowedThe insurer's proof of pre-claim IME nonattendance raised a factual issue as to the medical necessity of the supplies.
- Accessible & Advance Med. P.C. v Allstate Ins. Co. (2006 NY Slip Op 51599(U)) FollowedThe insurer's timely denials lacked a factual basis, and it failed to prove timely sending of the referenced peer review.
- Amaze Med. Supply Inc. v General Assur. Co. (2006 NY Slip Op 50910(U)) FollowedThe insurer's proof of mailing IME notices and the assignor's nonappearance raised a triable issue defeating the provider's cross motion.
- A.M. Med. Servs., P.C. v New York Cent. Mut. Ins. (2006 NY Slip Op 51662(U)) FollowedThe insurer proved mailing of one medical necessity denial but failed to prove verification mailing for four other claims.
- Amaze Med. Supply Inc. v Allstate Ins. Co. (2006 NY Slip Op 50909(U))The insurer established the assignor's failure to attend a pre-claim IME, defeating the provider's summary judgment motion.
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 Electric Ins. Co. (2005 NYSlipOp 50542(U))The assignor's selective IME attendance established receipt of all listed requests and raised a medical-necessity issue on the no-show denials.
- A.B. Med. Servs. PLLC v Peerless Ins. Co. (2006 NY Slip Op 26318)A provider need not prove assignment validity where the insurer neither sought verification nor raised an assignment defect in its denials.
- Jamhil Med., P.C. v Clarendon Natl. Ins. Co. (2012 NY Slip Op 51644(U))The insurer established timely mailing of IME notices and a denial based on the assignor's failure to appear for the scheduled IMEs. The president of the independent medical review service retained to schedule the examinations established timely mailing of the scheduling letters.
- Triboro Chiropractic v New York Cent. Mut. Fire Ins. Co. (2005 NY Slip Op 50110(U))An assignor's failure to attend IMEs requested before claim submission rebuts the claim forms' presumption of medical necessity.