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November 16, 2018

Nationwide Affinity Ins. Co. of Am. v Jamaica Wellness Med., P.C. (2018 NY Slip Op 07850)

https://www.beynensonlaw.com/case-law/nationwide-affinity-ins-co-of-am-v-jamaica-wellness-med-p-c-2018-ny-slip-op-07850/

Court
Appellate Division, Fourth Department
Decided
November 16, 2018
Citation
2018 NY Slip Op 07850 · 167 AD3d 192
Posture
Summary judgment
Outcome
Provider prevailed
Later treatment
Declined to follow in 1, contrasted (cf., but see) in 1 and followed in 3 later decisions (see Cited by)
Issues
EUO no-show Timeliness and preclusion
Cite as
Nationwide Affinity Ins. Co. of Am. v Jamaica Wellness Med., P.C., 167 AD3d 192 (4th Dept 2018)

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.

An EUO nonappearance defense is subject to preclusion when the insurer fails to issue a timely denial. The Appellate Division, Fourth Department, reversed the judgment, insofar as appealed from, denied the insurers' summary judgment motion, and vacated declarations relieving them of payment obligations. Under Insurance Law § 5106 (a) and 11 NYCRR 65-1.1 (d), submission to a reasonably requested EUO is a condition of payment under an existing policy, rather than a condition of coverage's existence. Rejecting contrary First Department precedent, the court applied the narrow no-coverage exception described in Fair Price Med. Supply Corp. v Travelers Indem. Co. The claims specialist's conclusory affidavit, unsupported by denial forms, failed to establish timely and proper denials.

Reported in New York Official Reports at Nationwide Affinity Ins. Co. of Am. v Jamaica Wellness Med., P.C. (2018 NY Slip Op 07850)

Nationwide Affinity Ins. Co. of Am. v Jamaica Wellness Med., P.C.
2018 NY Slip Op 07850 [167 AD3d 192]
November 16, 2018
Peradotto, J.
Appellate Division, Fourth Department
Published by New York State Law Reporting Bureau pursuant to Judiciary Law § 431.
As corrected through Wednesday, January 30, 2019

[*1]

Nationwide Affinity Insurance Company of America et al., Respondents,
v
Jamaica Wellness Medical, P.C., Appellant.

Fourth Department, November 16, 2018

Nationwide Affinity Ins. Co. of Am. v Jamaica Wellness Med., P.C., 2017 NY Slip Op 32943(U), reversed.

APPEARANCES OF COUNSEL

Kopelevich & Feldsherova, P.C., Brooklyn (Mikhail Kopelevich of counsel), for defendant-appellant.

Hollander Legal Group, P.C., Melville (Allan Hollander of counsel), and Harris J. Zakarin, P.C., for plaintiffs-respondents.

{**167 AD3d at 193} OPINION OF THE COURT

Peradotto, J.

In this appeal, we must determine whether an insurer in a no-fault benefits case may be precluded from asserting a defense premised upon the failure of the insured or that person’s assignee to appear at an examination under oath (EUO) where the insurer has not timely denied coverage. We hold that such a defense is subject to preclusion.

I.

Defendant is a medical professional corporation that was assigned claims for no-fault benefits by individuals who purportedly received treatment for injuries allegedly sustained in motor vehicle accidents. Defendant submitted bills for the services it purportedly rendered, along with the assignment of benefit forms, to the insurance carrier plaintiffs (hereinafter, Nationwide) seeking reimbursement pursuant to the No-Fault Law and regulations (see Insurance Law art 51; 11 NYCRR part{**167 AD3d at 194} 65). As part of an investigation of the validity of the claims, Nationwide sought additional information and requested that defendant submit to EUOs. Despite Nationwide’s repeated requests, defendant failed to appear at any of the scheduled EUOs.

Thereafter, Nationwide commenced this declaratory judgment action alleging that, by failing to appear for properly scheduled and noticed EUOs, defendant “breached a material condition precedent to coverage” under the insurance policies and no-fault regulations. Nationwide moved for summary judgment declaring that, as a result of such breach, it was under no obligation to pay or reimburse any of the subject claims, and defendant cross-moved for, inter [*2]alia, summary judgment dismissing the complaint.

Supreme Court subsequently granted the motion, and denied the cross motion. The court declared, among other things, that defendant breached a condition precedent to coverage by failing to appear at the scheduled EUOs and determined that Nationwide therefore had the right to deny all claims retroactively to the date of loss, regardless of whether it had issued timely denials.

As limited by its brief on appeal, defendant contends that the court erred in granting the motion because, in pertinent part, an insurer is precluded from asserting a litigation defense premised upon nonappearance at an EUO in the absence of a timely denial of coverage and that Nationwide failed to meet its burden of establishing that it issued timely denials. We agree with defendant for the reasons that follow.

II.

“The Comprehensive Motor Vehicle Insurance Reparations Act, commonly referred to as the ‘No-Fault Law’ (see Insurance Law art 51) is aimed at ensuring ‘prompt compensation for losses incurred by accident victims without regard to fault or negligence, to reduce the burden on the courts and to provide substantial premium savings to New York motorists’ ” (Viviane Etienne Med. Care, P.C. v Country-Wide Ins. Co., 25 NY3d 498, 504-505 [2015]).

As relevant here, “[w]here an insurer fails to pay or deny a [no-fault] claim within the requisite 30 days under the statute and{**167 AD3d at 195} regulations following its receipt of the proof of claim, the insurer is subject to substantial consequences, namely, preclusion from asserting a defense against payment of the claim” (id. at 506 [internal quotation marks omitted]; see Fair Price Med. Supply Corp. v Travelers Indem. Co., 10 NY3d 556, 562-563 [2008]; Hospital for Joint Diseases v Travelers Prop. Cas. Ins. Co., 9 NY3d 312, 317-318 [2007]; Presbyterian Hosp. in City of N.Y. v Maryland Cas. Co., 90 NY2d 274, 282 [1997], rearg denied 90 NY2d 937 [1997]). Although the preclusion remedy “may require an insurer to pay a no-fault claim it might not have had to honor if it had timely denied the claim,” the Court of Appeals has “emphasized that the great convenience of ‘prompt uncontested, first-party insurance benefits’ is ‘part of the price paid to eliminate common-law contested lawsuits’ ” (Viviane Etienne Med. Care, P.C., 25 NY3d at 506; see Fair Price Med. Supply Corp., 10 NY3d at 565; Presbyterian Hosp. in City of N.Y., 90 NY2d at 285).

The sole exception to the preclusion remedy “arises where an insurer raises lack of coverage as a defense” (Viviane Etienne Med. Care, P.C., 25 NY3d at 506).

“In such cases, an insurer who fails to issue a timely disclaimer is not prohibited from later raising th[at] defense because ‘the insurance policy does not contemplate coverage in the first instance, and requiring payment of a claim upon failure to timely disclaim would create coverage where it never existed’ ” (Hospital for Joint Diseases, 9 NY3d at 318).

The Court of Appeals has characterized the no-coverage exception to the preclusion remedy as an “exceptional exemption” of “narrow[ ] . . . sweep” (Central Gen. Hosp. v Chubb Group of Ins. Cos., 90 NY2d 195, 199 [1997]; see Fair Price Med. Supply Corp., 10 NY3d at 563-564; Hospital for Joint Diseases, 9 NY3d at 318). In determining whether a specific defense is subject to the preclusion remedy or falls under the no-coverage exception, a court must answer the following question: “Is the defense more like a ‘normal’ exception from coverage (e.g., a policy exclusion), or a lack of coverage in the first instance (i.e., a defense ‘implicat[ing] a coverage matter’)?” (Fair Price Med. Supply Corp., 10 NY3d at 565).

III.

The specific defense at issue here, based on nonappearance at EUOs, originates from the mandatory personal injury{**167 AD3d at 196} protection endorsement included as part of all automobile insurance policies (see 11 NYCRR 65-1.1 [b] [1]), which provides that “[n]o action shall lie against the [insurer] unless, as a condition precedent thereto, there shall have been full compliance with the terms of this coverage” (11 NYCRR 65-1.1 [d]). Those terms include providing written notice of the accident to the insurer, as well as written proof of claim for health service expenses (see id.). With respect to proof of claim, the endorsement states that, upon request by the insurer, the insured or that person’s assignee must, among other things, submit to EUOs as may be reasonably required (see id.; see also 11 NYCRR 65-3.5 [e]).

[*3]

We conclude that a defense premised upon nonappearance at an EUO is “more like a ‘normal’ exception from coverage (e.g., a policy exclusion)” than one involving “a lack of coverage in the first instance (i.e., a defense ‘implicat[ing] a coverage matter’)” (Fair Price Med. Supply Corp., 10 NY3d at 565; see also Hospital for Joint Diseases, 9 NY3d at 319-320; Presbyterian Hosp. in City of N.Y., 90 NY2d at 281-286; see generally Central Gen. Hosp., 90 NY2d at 199). Unlike defenses where preclusion thereof would result in coverage where it never existed, such as those premised upon the lack of a contract with the person claiming coverage or for the vehicle involved in the accident, the termination of the contract prior to the accident, or the cause of the purported injuries being something other than a vehicular accident (see Hospital for Joint Diseases, 9 NY3d at 319; Central Gen. Hosp., 90 NY2d at 200; Zappone v Home Ins. Co., 55 NY2d 131, 136-138 [1982]), the EUO nonappearance defense allows the insurer to avoid liability for the payment of no-fault benefits where the insured or assignee has breached a condition in an existing policy providing coverage (see IDS Prop. Cas. Ins. Co. v Stracar Med. Servs., P.C., 116 AD3d 1005, 1007 [2d Dept 2014]). In other words, “ ’coverage legitimately . . . exist[s]’ ” where there is a valid, unexpired policy under which a covered person seeks recovery following “an actual accident” involving a covered vehicle that results in the person sustaining “actual injuries” (Fair Price Med. Supply Corp., 10 NY3d at 565). In that event, the insured or assignee must meet certain obligations to the insurer to receive payment, including submitting to reasonably requested EUOs, and the insurer must meet certain obligations to the insured or assignee, including making timely payment of benefits that are supported by the requisite proof (see Insurance Law § 5106 [a]; 11 NYCRR 65-1.1 [d]). Thus, coverage under the policy exists in{**167 AD3d at 197} the first instance, but the failure of the insured or assignee to comply with the provision requiring submission to reasonably requested EUOs allows the insurer to deny payment of a claim based on such a material breach of the policy and thus relieves the insurer of liability for the payment of policy proceeds (see 11 NYCRR 65-1.1 [d]; Interboro Ins. Co. v Clennon, 113 AD3d 596, 597 [2d Dept 2014]; Westchester Med. Ctr. v Lincoln Gen. Ins. Co., 60 AD3d 1045, 1046-1047 [2d Dept 2009], lv denied 13 NY3d 714 [2009]).

Nationwide nonetheless contends that the court properly relied upon First Department precedent holding that the failure to appear at a duly requested EUO constitutes “a breach of a condition precedent to coverage under the no-fault policy, and therefore fits squarely within the [no-coverage] exception to the preclusion [remedy]” (Unitrin Advantage Ins. Co. v Bayshore Physical Therapy, PLLC, 82 AD3d 559, 560 [1st Dept 2011], lv denied 17 NY3d 705 [2011] [emphasis added]; see Mapfre Ins. Co. of N.Y. v Manoo, 140 AD3d 468, 470 [1st Dept 2016]; Hertz Corp. v Active Care Med. Supply Corp., 124 AD3d 411, 411 [1st Dept 2015]; Allstate Ins. Co. v Pierre, 123 AD3d 618, 618 [1st Dept 2014]). We disagree.

“Most conditions precedent describe acts or events which must occur before a party is obliged to perform a promise made pursuant to an existing contract, [which is] a situation to be distinguished conceptually from a condition precedent to the formation or existence of the contract itself . . . In the latter situation, no contract arises ‘unless and until the condition occurs’ ” (Oppenheimer & Co. v Oppenheim, Appel, Dixon & Co., 86 NY2d 685, 690 [1995]).

Contrary to the determination of the First Department, we conclude that the requirement that an insured or assignee submit to an EUO is not a condition precedent to the existence of coverage itself; rather, submission to a reasonably requested EUO represents an event that “must occur before [the insurer] is obliged to perform a promise made pursuant to an existing [policy],” i.e., rendering payment of benefits (id.; see 11 NYCRR 65-1.1 [d]). In sum, the failure to appear at a reasonably requested EUO constitutes a breach of an existing policy condition, which is distinguishable from lack of coverage in the first instance (see generally Fair Price Med. Supply Corp., 10 NY3d at 565; Central Gen. Hosp., 90 NY2d at 199).{**167 AD3d at 198}

We further agree with defendant that, contrary to the court’s determination and Nationwide’s contention, our holding in Interboro Ins. Co. v Tahir (129 AD3d 1687 [4th Dept 2015]) is not controlling. The no-coverage exception to the preclusion remedy was not at issue and the insurer disclaimed coverage in that case; thus, it is factually distinguishable and legally unpersuasive inasmuch as the broad language regarding vitiation of the contract for failure to comply with a condition precedent was not central to the holding and did not account for the conceptual differences between types of conditions precedent (see id. at 1688).

IV.

We agree with defendant that, inasmuch as the defense based on nonappearance at an [*4]EUO is subject to the preclusion remedy, Nationwide was required to establish that it issued timely denials on that ground, and that Nationwide failed to meet its initial burden on the motion. The assertions in the affidavit of Nationwide’s claims specialist that Nationwide issued timely denial forms to defendant for nonappearance at the EUOs are conclusory and unsupported by any such denial forms; therefore, Nationwide did not establish as a matter of law that it issued timely and proper denials. Inasmuch as Nationwide “failed to establish [its] prima facie entitlement to judgment as a matter of law on the issue of [its] timely and proper denial of coverage, summary judgment should have been denied regardless of the sufficiency of . . . defendant’s opposition” (Progressive Cas. Ins. Co. v Infinite Ortho Prods., Inc., 127 AD3d 1050, 1052 [2d Dept 2015]).

V.

Accordingly, we conclude that the judgment insofar as appealed from should be reversed, the motion should be denied, and the declarations should be vacated.

Centra, J.P., Carni, Curran and Winslow, JJ., concur.

It is hereby ordered that the judgment insofar as appealed from is unanimously reversed on the law without costs, the motion is denied, and the declarations are vacated.

On the authority map

  • No-show: coverage defense or precludable? No-show defense is subject to preclusion and fails for want of a timely, proper denial

Cited in this decision

A label shows how this decision treated the case it cites.

  • Viviane Etienne Med. Care, P.C. v Country-Wide Ins. Co. (2015 NY Slip Op 04787) FollowedA provider establishes entitlement to summary judgment on overdue no-fault claims with admissible proof of mailing and receipt of statutory claim forms.
  • Fair Price Med. Supply Corp. v Travelers Indem. Co. (2008 NY Slip Op 04946) FollowedAn insurer's defense that billed supplies were never delivered is subject to preclusion for an untimely denial.
  • Hospital for Joint Diseases v Travelers Prop. Cas. Ins. Co. (2007 NY Slip Op 09067) FollowedAn insurer that fails to timely seek verification of an assignment cannot later contest its validity when the underlying claim is covered.
  • IDS Prop. Cas. Ins. Co. v Stracar Med. Servs., P.C. (2014 NY Slip Op 02902) FollowedThe providers' unexcused EUO nonappearances breached a condition precedent to coverage and warranted summary judgment for the insurer.
  • Interboro Ins. Co. v Clennon (2014 NY Slip Op 00092)The assignor's two EUO nonappearances supported a declaration that the providers were not entitled to no-fault benefits.
  • Westchester Med. Ctr. v Lincoln Gen. Ins. Co. (2009 NY Slip Op 02589)The insurer's investigation letters did not toll the 30-day period to pay or deny the provider's claim.
  • Unitrin Advantage Ins. Co. v Bayshore Physical Therapy, PLLC (2011 NY Slip Op 01948) Declined to followAn assignor's failure to attend required IMEs permits retroactive denial of no-fault claims regardless of denial timeliness.
  • Mapfre Ins. Co. of N.Y. v Manoo (2016 NY Slip Op 04446) Declined to followEUO requests made before receipt of a claim form are not subject to the verification notice requirements of 11 NYCRR 65-3.5 and 65-3.6.
  • Hertz Corp. v Active Care Med. Supply Corp. (2015 NY Slip Op 00212) Declined to followA provider's failure to attend EUOs violates a condition precedent to no-fault coverage and vitiates the policy.
  • Allstate Ins. Co. v Pierre (2014 NY Slip Op 08921) Declined to followFailure to attend requested EUOs breaches a no-fault coverage condition, regardless of denial timeliness or willfulness.
  • Interboro Ins. Co. v Tahir (2015 NY Slip Op 05378) DistinguishedThe insurer's default motion was granted on appeal only against the corporate provider, given deficient service on the other two defendants.
  • Progressive Cas. Ins. Co. v Infinite Ortho Prods., Inc. (2015 NY Slip Op 03340) FollowedThe insurers failed to establish timely and proper mailing of denials based on missing verification and EUO nonappearance.

Cited by

A label shows how the later decision treated this one.

  • State Farm Fire & Cas. Co. v Atlantic Diagnostic, L.L.C. (2024 NY Slip Op 50436(U)) Declined to followAn assignor who appears for an EUO must sign the transcript on request even if the insurer has not proved its EUO request timely.
  • Liberty Mut. Ins. Co. v Brutus (2022 NY Slip Op 50799(U)) Contrasted (cf., but see)An insurer's material-misrepresentation defense is subject to the 30-day no-fault deadline for paying or denying claims.
  • Island Life Chiropractic Pain Care, PLLC v 21st Century Ins. Co. (2021 NY Slip Op 21340) FollowedAn untimely EUO no-show denial of one claim does not waive the defense against later claims that are individually timely denied.
  • Nationwide Affinity Ins. Co. of Am. v Jamaica Wellness Med., P.C. (2020 NY Slip Op 00971) FollowedThe insurers' successive summary judgment motion was entertained because an intervening appeal clarified the proof required for EUO nonappearance.
  • Nationwide Affinity Ins. Co. of Am. v PFJ Med. Care, P.C. (2020 NY Slip Op 00972) FollowedThe insurers justified renewal with previously known denial evidence after intervening precedent made EUO nonappearance subject to preclusion.
  • American Tr. Ins. Co. v Acosta (2022 NY Slip Op 01097)The insurer failed to establish compliance with IME scheduling deadlines, defeating summary judgment based on nonappearance.

Similar decisions

  • FJL Med. Servs., P.C. v Nationwide Ins. (2022 NY Slip Op 51213(U))An insurer cannot extend the claim determination toll after a second EUO nonappearance by unilaterally scheduling further EUOs. The insurer recorded four provider nonappearances and denied the claim more than 30 days after the second.
  • Quality Health Supply Corp. v Nationwide Ins. (2023 NY Slip Op 02689)The insurer established timely EUO notices and denials, proper follow-up, and the assignor's nonappearances.
  • Allstate Chiropractic, P.C. v Nationwide Affinity Ins. Co. of Am. (2023 NY Slip Op 50299(U))The insurer failed to establish timely denials because scheduling another EUO did not extend the deadline after the second nonappearance.
  • Bridgeview Supply Corp. v Nationwide Mut. Ins. Co. (2026 NY Slip Op 50190(U))An insurer need not state objective reasons for requesting EUOs as part of its prima facie showing for summary judgment based on nonappearance.
  • Nationwide Affinity Ins. Co. of Am. v George (2020 NY Slip Op 02801)The insurer proved timely EUO notices, two nonappearances by each assignor, and timely denials; the providers raised no factual issue.
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