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January 5, 2022

Optimum Health Acupuncture, P.C. v Integon Natl. Ins. Co. (2022 NY Slip Op 50068(U))

https://www.beynensonlaw.com/case-law/optimum-health-acupuncture-p-c-v-integon-natl-ins-co-2022-ny-slip-op50068u/

Court
District Court of Suffolk County, Fourth District
Judge
James F. Matthews, J.
Decided
January 5, 2022
Citation
2022 NY Slip Op 50068(U)
Posture
Summary judgment
Outcome
Insurer prevailed
Issues
Fee schedule Medical necessity
Legal questions
Lack of medical necessity · Proving a fee schedule defense · Proof of mailing (see the maps)
Cite as
Optimum Health Acupuncture, P.C. v Integon Natl. Ins. Co., 2022 NY Slip Op 50068(U) (Dist Ct, Suffolk County, 4th Dist 2022)

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.

The provider failed to raise factual issues on fee-schedule reductions and medical necessity because its expert affidavits were missing. The District Court, Suffolk County, granted the insurer's summary judgment motion under CPLR 3212 (b) and dismissed the complaint. The insurer submitted a certified professional coder's affidavit supporting fee-schedule reductions, along with IME and peer review reports supporting lack of medical necessity. Although the provider's opposition purported to attach rebuttal affidavits from its coding and medical experts, none were submitted. Counsel's analysis, without personal knowledge or supporting expert evidence, could not defeat the motion. The insurer's calculations and medical opinions therefore remained unrebutted.

Reported in New York Official Reports at Optimum Health Acupuncture, P.C. v Integon Natl. Ins. Co. (2022 NY Slip Op 50068(U))



Optimum Health Acupuncture, P.C., a/a/o CLYDE BOWAL, Plaintiff,

against

Integon National Ins. Co., Defendant.

Index No. CV-1526-20/SM
James F. Matthews, J.

Upon the following papers numbered 1 to 65 read on this motion by defendant for an order seeking Summary Judgment of dismissal ; by Notice of Motion/Order to Show Cause and supporting papers 1-4,61 ; Notice of Cross Motion and supporting papers ; Answering Affidavits and supporting papers 62,63 ; Replying Affidavits and supporting papers 64,65 ; Filed papers; Other exhibits: 5-60, (and after hearing counsel in support of and opposed to the motion), it is

ORDERED that the motion by defendant for summary judgment dismissing plaintiff’s complaint pursuant to CPLR 3212(b), is granted.

Plaintiff medical provider seeks reimbursement from defendant insurer for assigned first party no-fault benefits for medical dates of service (“DOS”) rendered to plaintiff’s assignor from 02/06/2019 through 03/19/2020, for injuries sustained from a car accident of 01/28/2019, in the outstanding sum of $7,399.77, under New York’s No-Fault Law.

Defendant now moves for summary judgment dismissing the complaint pursuant to CPLR 3212(b), supported by the affidavit of its Claims Supervisor, Danuta Fudali, which asserts, inter alia, that defendant timely mailed its NF-10 Denial Of Claim forms (“denials”) and Explanation of Benefits (“EOB’s”) to plaintiff, pursuant to the practices and procedures it established to ensure timely deliver of its mailings to the intended recipient, thereby creating a presumption of receipt. The denials were based upon defendant’s payment in full for plaintiff’s submissions of excessive billing not compiled in accordance with the Workers’ Compensation [*2]Fee Schedule (“Fee Schedule”), pursuant to the findings in the affidavit of Carolyn Mallory, C.P.C. (“Certified Professional Coder”)[FN1] , and the lack of medical necessity for certain chiropractic and acupuncture billing, as supported by the Independent Medical Examination (“IME”) and report of Dr. John Iozzio, D.C., L.Ac., dated 03/26/2019, the IME report of Dr. John Iozzio dated 05/02/2019, and the peer review report of Dr. Daniel Sposta, D.C., L.Ac., dated 05/15/2019, which cut off any further chiropractic and acupuncture treatments as of 04/22/2019 and 05/23/2019, respectively.

In opposition to the motion for summary judgment, plaintiff asserts it attached to its papers as an exhibit, the affidavit of Dr. Vadim Dolsky, L.Ac., to rebut the claims of Dr. Iozzio and Dr. Sposta, by demonstrating plaintiff’s assignor was symptomatic and required the treatments provided by the treating providers; that Dr. Iozzio’s IME reports concede that the evaluations and treatments prior to the IME dates were medically necessary; that defendant’s IME reports failed to demonstrate the disputed services were inconsistent with generally accepted medical or professional practices; and Dr. Dolsky’s professional opinion differs from that stated by defendant’s experts, thereby raising a question of fact requiring a trial.

In addition, plaintiff asserts it attached to its papers as an exhibit, the affidavit of Priti Kumar, C.P.C., to rebut the facts and opinions on the proper use of the fee schedule, in opposition to the opinion expressed by Carolyn Mallory, C.P.C. on behalf of defendant. Plaintiff contends the difference of opinion of each party’s expert raises a question of fact, which requires a trial.

In reply to plaintiff’s opposition papers, defendant urges the Court to ignore the purported findings of both Dr. Vadim Dolsky, L.Ac., and that of Priti Kumar, C.P.C., as there are no affidavits or exhibits attached to plaintiff’s papers as an exhibit. Indeed, a search by the Court for the existence of any exhibits or affidavits from plaintiff proved useless, as there is none to be found.

A proponent of a motion for summary judgment must make a prima facie showing of entitlement to judgment as a matter of law with proof in admissible form sufficient to establish the lack of any material issues of fact (see Alvarez v Prospect Hospital, 68 NY2d 320, 324 [1986]; Winegrad v New York Univ. Med. Ctr., 64 NY2d 851, 853 [1985]; Zuckerman v City of New York, 49 NY2d 557,562 [1980]; see also Manhattan Medical v State Farm Mut. Ins. Co., 20 Misc 3d 1144[A][Civ. Ct. Richmond Cty. 2008]).

Once a showing of entitlement to summary judgment has been made, the burden shifts to the party opposing the motion for summary judgment, to produce evidentiary proof in admissible form sufficient to establish the existence of material issues of fact which require a trial of the action (see CPLR 3212 [b]; Alvarez v Prospect Hospital, supra; Zuckerman v City of New York, supra).

An attorney’s affirmation which demonstrates no personal knowledge of the facts, is insufficient to defeat a motion for summary judgment, but may serve as a vehicle for the submission of acceptable attachments, which do provide evidentiary proof in admissible form (see Zuckerman v City of New York, supra).

Here, the Court determines defendant has satisfied its burden of demonstrating the existence and following of its standard office practices and procedures for the timely and proper mailing of its NF-10 denial of claim forms and EOR’s to plaintiff (see Delta Diagnostic Radiology, P.C. v Chubb Group of Ins., 17 Misc 3d 16 [App Term, 2nd Dept, 2007]). Defendant’s mailing methods were sufficient to create a rebuttable presumption of proper mailing (see St. Vincent’s Hosp. of Richmond v GEICO, 50 AD3d 1123, 1124 [2nd Dept 2008]; New York Presbyt. Hosp. v Allstate Ins. Co.,29 AD3d 547 [2nd Dept 2006]; Gentlecare Ambulatory Anesthesia Servs. v GEICO Ins. Co., 57 Misc 3d 150[A][App Term, 2d, 11th & 13th Jud Dists 2017]). “…Proof of proper mailing gives rise to a presumption that the item was received by the addressee” (see Residential Holding Corp. v Scottsdale Ins. Co., 286 AD2d 679, 680 [2nd Dept 2001]), which presumptions of receipt, were not refuted or denied by plaintiff in the instant matter. Plaintiff’s arguments in opposition are unavailing.

The Court further determines that defendant has made a prima facie showing of entitlement to summary judgment as a matter of law with proof in admissible form sufficient to establish the lack of any material issues of fact, which has not been refuted by plaintiff (see Alvarez v Prospect Hospital,supra]; Winegrad v New York Univ. Med. Center, supra; Zuckerman v City of New York, supra).

The failure to submit a rebuttal affidavit from plaintiff’s C.P.C. expert on the contested fee schedule issues, leaves only the opposition analysis of plaintiff’s attorney, with no personal knowledge of the facts, unsupported by expert witness testimony as to the use and interpretation of the fee schedules in the context of defendant’s components and calculations of the alleged maximum permissible fee (see Murali v Upton, 175 Misc 2d 186, 187-188 [Civ Ct, NY Cty, 1997]).

In addition, the failure to submit a rebuttal affidavit from plaintiff’s expert physician showing the medical necessity of its billing in a non-conclusory manner and meaningful way, rebutting the issues raised in the insurer’s IME and peer review reports, fails to demonstrate the existence of a triable issue of fact as to whether there was a lack of medical necessity for the medical services at issue (see Throgs Neck Multicare, P.C. v Mercury Ins. Co., 52 Misc 3d 138[a}[App Term, 2nd Dept, 9th & 10th Jud Dists 2016]), and leaves the conclusions of defendant’s medical experts un-refuted (see Pan Chiropractic, P.C. v Mercury Ins. Co., 24 Misc 3d 136[A][App Term, 2nd, 11th & 13th Jud Dists 2009]).

“The law is well settled that a party, in opposition to a motion for summary judgment, must assemble and lay bare affirmative proof to demonstrate that the matters alleged are real and capable of being established upon trial” (see Nelson v Lundy, 298 AD2d 689, 690 [3rd Dept 2002]; see also Wasson v Bond, 80 AD3d 1114 [3rd Dept 2011]). The plaintiff’s papers fail to meet this standard and accordingly, judgment is granted in favor of defendant and the complaint is dismissed (see Jamil M. Abraham, M.D., P.C. v Country Wide Ins. Co.,3 Misc 3d 130[A][App Term, 2nd & 11th Jud Dists 2004]; Murali v Upton, supra).

Accordingly, the motion for summary judgment by defendant pursuant to CPLR 3212(b), is granted. The foregoing constitutes the decision and order of this Court.

Dated: January 5, 2022
J.D.C.

Footnotes

Footnote 1:Defendant’s expert Coder states under oath that in the event medical necessity is found at a trial, the amounts to be allowed under the fee schedule would be $447.32 for Bills 1 through 6, and $3,798.60 for Bills 7 through 46 (see page 46 of Carolyn Mallory’s affidavit).

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.

Lack of medical necessity

Open the full map

Did the insurer’s proof establish lack of medical necessity, and did the provider’s evidence rebut it?

This decision: Insurer's proof established lack of medical necessity and the provider failed to rebut it

Held the IME and peer review reports went unrefuted because the provider's claimed rebuttal affidavit from its acupuncturist was not actually attached to its papers.

  • Appellate DivisionApp Div 9
  • Appellate TermApp Term 521
  • Trial courtsTrial 87
2022, Appellate Division: 2 decisions (2 Insurer's proof insufficient)2020, Appellate Division: 1 decision (1 Provider's rebuttal sufficient)2019, Appellate Division: 1 decision (1 Insurer's proof insufficient)2016, Appellate Division: 2 decisions (1 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2008, Appellate Division: 1 decision (1 Insurer's proof insufficient)2007, Appellate Division: 2 decisions (2 Insurer raised triable issue)2023, Appellate Term: 1 decision (1 Provider's rebuttal sufficient)2022, Appellate Term: 1 decision (1 Unrebutted, insurer prevails)2021, Appellate Term: 4 decisions (4 Unrebutted, insurer prevails)2020, Appellate Term: 5 decisions (1 Unrebutted, insurer prevails, 2 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 1 Trial error, new trial)2019, Appellate Term: 15 decisions (8 Unrebutted, insurer prevails, 4 Insurer's proof insufficient, 3 Trial error, new trial)2018, Appellate Term: 13 decisions (7 Unrebutted, insurer prevails, 2 Provider's rebuttal sufficient, 4 Trial error, new trial)2017, Appellate Term: 20 decisions (5 Unrebutted, insurer prevails, 7 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 7 Trial error, new trial)2016, Appellate Term: 28 decisions (16 Unrebutted, insurer prevails, 7 Provider's rebuttal sufficient, 3 Insurer raised triable issue, 2 Insurer's proof insufficient)2015, Appellate Term: 22 decisions (9 Unrebutted, insurer prevails, 9 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 2 Insurer's proof insufficient, 1 Trial error, new trial)2014, Appellate Term: 40 decisions (16 Unrebutted, insurer prevails, 22 Provider's rebuttal sufficient, 1 Insurer's proof insufficient, 1 Trial error, new trial)2013, Appellate Term: 57 decisions (40 Unrebutted, insurer prevails, 12 Provider's rebuttal sufficient, 1 Insurer raised triable issue, 2 Insurer's proof insufficient, 2 Trial error, new trial)2012, Appellate Term: 76 decisions (54 Unrebutted, insurer prevails, 10 Provider's rebuttal sufficient, 2 Insurer raised triable issue, 5 Insurer's proof insufficient, 5 Trial error, new trial)2011, Appellate Term: 56 decisions (42 Unrebutted, insurer prevails, 6 Provider's rebuttal sufficient, 2 Insurer raised triable issue, 2 Insurer's proof insufficient, 4 Trial error, new trial)2010, Appellate Term: 66 decisions (50 Unrebutted, insurer prevails, 5 Provider's rebuttal sufficient, 9 Insurer raised triable issue, 2 Insurer's proof insufficient)2009, Appellate Term: 32 decisions (17 Unrebutted, insurer prevails, 2 Provider's rebuttal sufficient, 9 Insurer raised triable issue, 4 Insurer's proof insufficient)2008, Appellate Term: 29 decisions (14 Unrebutted, insurer prevails, 9 Insurer raised triable issue, 6 Insurer's proof insufficient)2007, Appellate Term: 9 decisions (3 Unrebutted, insurer prevails, 3 Insurer raised triable issue, 2 Insurer's proof insufficient, 1 Trial error, new trial)2006, Appellate Term: 20 decisions (1 Unrebutted, insurer prevails, 11 Insurer raised triable issue, 8 Insurer's proof insufficient)2005, Appellate Term: 16 decisions (6 Insurer raised triable issue, 10 Insurer's proof insufficient)2004, Appellate Term: 10 decisions (1 Insurer raised triable issue, 9 Insurer's proof insufficient)2003, Appellate Term: 1 decision (1 Insurer raised triable issue)2022, Trial courts: 6 decisions (4 Unrebutted, insurer prevails, 1 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2021, Trial courts: 2 decisions (1 Unrebutted, insurer prevails, 1 Provider's rebuttal sufficient)2017, Trial courts: 2 decisions (1 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2015, Trial courts: 1 decision (1 Unrebutted, insurer prevails)2014, Trial courts: 3 decisions (2 Provider's rebuttal sufficient, 1 Insurer's proof insufficient)2013, Trial courts: 2 decisions (1 Unrebutted, insurer prevails, 1 Trial error, new trial)2012, Trial courts: 7 decisions (4 Unrebutted, insurer prevails, 3 Insurer's proof insufficient)2011, Trial courts: 4 decisions (4 Insurer's proof insufficient)2010, Trial courts: 10 decisions (2 Unrebutted, insurer prevails, 7 Insurer's proof insufficient, 1 Trial error, new trial)2009, Trial courts: 5 decisions (2 Unrebutted, insurer prevails, 2 Insurer raised triable issue, 1 Insurer's proof insufficient)2008, Trial courts: 11 decisions (6 Unrebutted, insurer prevails, 5 Insurer's proof insufficient)2007, Trial courts: 5 decisions (1 Provider's rebuttal sufficient, 4 Insurer's proof insufficient)2006, Trial courts: 9 decisions (2 Unrebutted, insurer prevails, 1 Insurer raised triable issue, 6 Insurer's proof insufficient)2005, Trial courts: 9 decisions (2 Unrebutted, insurer prevails, 1 Insurer raised triable issue, 6 Insurer's proof insufficient)2004, Trial courts: 8 decisions (1 Unrebutted, insurer prevails, 1 Insurer raised triable issue, 5 Insurer's proof insufficient, 1 Trial error, new trial)2003, Trial courts: 1 decision (1 Insurer's proof insufficient)2026, Trial courts: 1 decision (1 Provider's rebuttal sufficient)2025, Trial courts: 1 decision (1 Unrebutted, insurer prevails)This decision
20052010201520202025
Unrebutted, insurer prevailsProvider's rebuttal sufficientInsurer raised triable issueInsurer's proof insufficientTrial error, new trialThis decisionCites it or cited by itCited or followed

Of the 617 decisions on this question in the Second Department courts and the Court of Appeals, 315 (this one included) are in the same category.

Proving a fee schedule defense

Open the full map

Did the insurer prove that the amount billed exceeded the applicable workers’ compensation fee schedule?

This decision: Insurer proved the billed amount exceeded the applicable fee schedule

Held the certified coder's affidavit established the billing exceeded the fee schedule, and the provider's missing coder affidavit left only an attorney's opposition without personal knowledge, raising no triable issue.

  • Court of AppealsCt App 1
  • Appellate DivisionApp Div 6
  • Appellate TermApp Term 239
  • Trial courtsTrial 39
2016, Court of Appeals: 1 decision (1 Excess shown)2022, Appellate Division: 1 decision (1 Excess shown)2020, Appellate Division: 1 decision (1 Not established; open)2019, Appellate Division: 2 decisions (1 Excess shown, 1 Defense rejected)2015, Appellate Division: 1 decision (1 Excess shown)2008, Appellate Division: 1 decision (1 Excess shown)2022, Appellate Term: 8 decisions (4 Excess shown, 2 Not established; open, 1 Defense rejected, 1 Split by charge)2021, Appellate Term: 5 decisions (1 Excess shown, 1 Not established; open, 3 Defense rejected)2020, Appellate Term: 10 decisions (6 Excess shown, 3 Not established; open, 1 Split by charge)2019, Appellate Term: 16 decisions (13 Excess shown, 2 Not established; open, 1 Split by charge)2018, Appellate Term: 10 decisions (9 Excess shown, 1 Split by charge)2017, Appellate Term: 47 decisions (27 Excess shown, 15 Not established; open, 5 Split by charge)2016, Appellate Term: 21 decisions (11 Excess shown, 7 Not established; open, 1 Defense rejected, 2 Split by charge)2015, Appellate Term: 13 decisions (10 Excess shown, 3 Not established; open)2014, Appellate Term: 13 decisions (7 Excess shown, 5 Not established; open, 1 Split by charge)2013, Appellate Term: 13 decisions (3 Excess shown, 8 Not established; open, 2 Split by charge)2012, Appellate Term: 20 decisions (15 Excess shown, 3 Not established; open, 1 Defense rejected, 1 Split by charge)2011, Appellate Term: 18 decisions (8 Excess shown, 5 Not established; open, 5 Split by charge)2010, Appellate Term: 15 decisions (7 Excess shown, 3 Not established; open, 3 Defense rejected, 2 Split by charge)2009, Appellate Term: 6 decisions (4 Excess shown, 2 Not established; open)2008, Appellate Term: 2 decisions (1 Excess shown, 1 Not established; open)2007, Appellate Term: 5 decisions (3 Excess shown, 2 Not established; open)2006, Appellate Term: 2 decisions (1 Not established; open, 1 Defense rejected)2005, Appellate Term: 5 decisions (1 Not established; open, 4 Defense rejected)2004, Appellate Term: 3 decisions (1 Not established; open, 2 Defense rejected)2003, Appellate Term: 2 decisions (2 Defense rejected)2023, Appellate Term: 1 decision (1 Excess shown)2025, Appellate Term: 1 decision (1 Not established; open)2026, Appellate Term: 3 decisions (2 Excess shown, 1 Not established; open)2022, Trial courts: 4 decisions (2 Excess shown, 2 Not established; open)2021, Trial courts: 4 decisions (1 Excess shown, 3 Not established; open)2017, Trial courts: 2 decisions (2 Excess shown)2016, Trial courts: 2 decisions (1 Excess shown, 1 Not established; open)2015, Trial courts: 1 decision (1 Not established; open)2013, Trial courts: 2 decisions (1 Not established; open, 1 Defense rejected)2012, Trial courts: 2 decisions (1 Not established; open, 1 Defense rejected)2011, Trial courts: 1 decision (1 Excess shown)2010, Trial courts: 2 decisions (1 Defense rejected, 1 Split by charge)2009, Trial courts: 2 decisions (1 Excess shown, 1 Defense rejected)2008, Trial courts: 1 decision (1 Not established; open)2007, Trial courts: 2 decisions (2 Not established; open)2006, Trial courts: 3 decisions (3 Defense rejected)2005, Trial courts: 3 decisions (2 Excess shown, 1 Not established; open)2004, Trial courts: 2 decisions (2 Defense rejected)2024, Trial courts: 1 decision (1 Defense rejected)2026, Trial courts: 3 decisions (2 Not established; open, 1 Split by charge)2018, Trial courts: 2 decisions (2 Not established; open)This decision
20052010201520202025
Excess shownNot established; openDefense rejectedSplit by chargeThis decision

Of the 285 decisions on this question in the Second Department courts and the Court of Appeals, 147 (this one included) are in the same category.

Proof of mailing

Open the full map

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 (rules on the question, but another ground decided the case)

Held the claims supervisor's affidavit showed standard office practices for timely and proper mailing of the denials and EOBs, creating an unrebutted presumption of receipt.

  • Court of AppealsCt App 1
  • Appellate DivisionApp Div 37
  • Appellate TermApp Term 1,214
  • Trial courtsTrial 148
2015, Court of Appeals: 1 decision (1 Provider proved mailing)2023, Appellate Division: 1 decision (1 Insurer proved mailing)2020, Appellate Division: 1 decision (1 Insurer proved mailing)2016, Appellate Division: 3 decisions (1 Insurer proved mailing, 2 Insurer failed to prove)2015, Appellate Division: 2 decisions (2 Insurer failed to prove)2014, Appellate Division: 3 decisions (2 Insurer proved mailing, 1 Provider proved mailing)2013, Appellate Division: 1 decision (1 Provider proved mailing)2012, Appellate Division: 1 decision (1 Provider proved mailing)2011, Appellate Division: 6 decisions (3 Insurer proved mailing, 1 Insurer failed to prove, 2 Provider proved mailing)2010, Appellate Division: 1 decision (1 Provider proved mailing)2008, Appellate Division: 2 decisions (2 Insurer proved mailing)2007, Appellate Division: 7 decisions (1 Insurer proved mailing, 1 Insurer failed to prove, 3 Provider proved mailing, 1 Provider failed to prove, 1 Mixed rulings)2006, Appellate Division: 3 decisions (2 Insurer failed to prove, 1 Provider failed to prove)2005, Appellate Division: 2 decisions (2 Insurer failed to prove)2004, Appellate Division: 3 decisions (2 Insurer failed to prove, 1 Triable issue on mailing)2026, Appellate Division: 1 decision (1 Insurer failed to prove)2023, Appellate Term: 6 decisions (5 Insurer proved mailing, 1 Triable issue on mailing)2022, Appellate Term: 44 decisions (32 Insurer proved mailing, 3 Insurer failed to prove, 1 Provider proved mailing, 3 Provider failed to prove, 5 Triable issue on mailing)2021, Appellate Term: 21 decisions (13 Insurer proved mailing, 2 Insurer failed to prove, 5 Triable issue on mailing, 1 Mixed rulings)2020, Appellate Term: 31 decisions (24 Insurer proved mailing, 2 Insurer failed to prove, 5 Triable issue on mailing)2019, Appellate Term: 81 decisions (59 Insurer proved mailing, 5 Insurer failed to prove, 2 Provider proved mailing, 2 Provider failed to prove, 12 Triable issue on mailing, 1 Mixed rulings)2018, Appellate Term: 74 decisions (46 Insurer proved mailing, 16 Insurer failed to prove, 1 Provider failed to prove, 10 Triable issue on mailing, 1 Mixed rulings)2017, Appellate Term: 115 decisions (60 Insurer proved mailing, 26 Insurer failed to prove, 4 Provider proved mailing, 2 Provider failed to prove, 21 Triable issue on mailing, 2 Mixed rulings)2016, Appellate Term: 103 decisions (44 Insurer proved mailing, 30 Insurer failed to prove, 3 Provider proved mailing, 2 Provider failed to prove, 21 Triable issue on mailing, 3 Mixed rulings)2015, Appellate Term: 97 decisions (66 Insurer proved mailing, 10 Insurer failed to prove, 1 Provider proved mailing, 3 Provider failed to prove, 9 Triable issue on mailing, 8 Mixed rulings)2014, Appellate Term: 68 decisions (55 Insurer proved mailing, 4 Insurer failed to prove, 2 Provider proved mailing, 3 Triable issue on mailing, 4 Mixed rulings)2013, Appellate Term: 73 decisions (62 Insurer proved mailing, 6 Insurer failed to prove, 1 Provider proved mailing, 1 Provider failed to prove, 3 Mixed rulings)2012, Appellate Term: 110 decisions (87 Insurer proved mailing, 14 Insurer failed to prove, 1 Provider proved mailing, 3 Provider failed to prove, 1 Triable issue on mailing, 4 Mixed rulings)2011, Appellate Term: 69 decisions (56 Insurer proved mailing, 8 Insurer failed to prove, 2 Provider proved mailing, 1 Triable issue on mailing, 2 Mixed rulings)2010, Appellate Term: 78 decisions (67 Insurer proved mailing, 4 Insurer failed to prove, 2 Provider proved mailing, 2 Provider failed to prove, 1 Triable issue on mailing, 2 Mixed rulings)2009, Appellate Term: 53 decisions (29 Insurer proved mailing, 11 Insurer failed to prove, 6 Provider proved mailing, 3 Provider failed to prove, 4 Mixed rulings)2008, Appellate Term: 28 decisions (13 Insurer proved mailing, 11 Insurer failed to prove, 2 Provider proved mailing, 1 Provider failed to prove, 1 Mixed rulings)2007, Appellate Term: 30 decisions (9 Insurer proved mailing, 16 Insurer failed to prove, 3 Provider proved mailing, 2 Mixed rulings)2006, Appellate Term: 75 decisions (6 Insurer proved mailing, 19 Insurer failed to prove, 21 Provider proved mailing, 21 Provider failed to prove, 8 Mixed rulings)2005, Appellate Term: 27 decisions (2 Insurer proved mailing, 14 Insurer failed to prove, 7 Provider proved mailing, 3 Provider failed to prove, 1 Mixed rulings)2004, Appellate Term: 12 decisions (1 Insurer proved mailing, 4 Insurer failed to prove, 3 Provider proved mailing, 2 Provider failed to prove, 1 Triable issue on mailing, 1 Mixed rulings)2003, Appellate Term: 3 decisions (3 Provider proved mailing)2024, Appellate Term: 4 decisions (2 Insurer proved mailing, 1 Insurer failed to prove, 1 Provider failed to prove)2025, Appellate Term: 4 decisions (3 Insurer proved mailing, 1 Provider proved mailing)2026, Appellate Term: 8 decisions (3 Insurer proved mailing, 3 Insurer failed to prove, 2 Triable issue on mailing)2023, Trial courts: 4 decisions (2 Insurer proved mailing, 2 Provider proved mailing)2022, Trial courts: 5 decisions (2 Insurer proved mailing, 2 Provider proved mailing, 1 Mixed rulings)2021, Trial courts: 18 decisions (12 Insurer proved mailing, 1 Provider proved mailing, 3 Provider failed to prove, 2 Mixed rulings)2020, Trial courts: 5 decisions (1 Insurer proved mailing, 2 Provider proved mailing, 2 Mixed rulings)2019, Trial courts: 4 decisions (3 Insurer failed to prove, 1 Triable issue on mailing)2018, Trial courts: 1 decision (1 Insurer proved mailing)2017, Trial courts: 7 decisions (5 Insurer proved mailing, 2 Insurer failed to prove)2016, Trial courts: 4 decisions (2 Insurer proved mailing, 1 Provider proved mailing, 1 Triable issue on mailing)2015, Trial courts: 3 decisions (3 Provider proved mailing)2013, Trial courts: 4 decisions (3 Insurer proved mailing, 1 Insurer failed to prove)2012, Trial courts: 10 decisions (5 Insurer proved mailing, 2 Insurer failed to prove, 2 Provider proved mailing, 1 Triable issue on mailing)2011, Trial courts: 4 decisions (2 Insurer proved mailing, 1 Insurer failed to prove, 1 Provider failed to prove)2010, Trial courts: 6 decisions (3 Insurer proved mailing, 1 Insurer failed to prove, 2 Provider proved mailing)2009, Trial courts: 9 decisions (4 Insurer proved mailing, 2 Insurer failed to prove, 3 Provider proved mailing)2008, Trial courts: 13 decisions (3 Insurer proved mailing, 1 Insurer failed to prove, 7 Provider proved mailing, 1 Provider failed to prove, 1 Mixed rulings)2007, Trial courts: 8 decisions (1 Insurer proved mailing, 5 Insurer failed to prove, 2 Provider proved mailing)2006, Trial courts: 7 decisions (1 Insurer proved mailing, 6 Insurer failed to prove)2005, Trial courts: 15 decisions (2 Insurer proved mailing, 8 Insurer failed to prove, 1 Provider proved mailing, 4 Provider failed to prove)2004, Trial courts: 10 decisions (5 Insurer failed to prove, 2 Provider proved mailing, 3 Provider failed to prove)2024, Trial courts: 2 decisions (1 Insurer failed to prove, 1 Provider failed to prove)2025, Trial courts: 2 decisions (2 Insurer proved mailing)2026, Trial courts: 7 decisions (3 Insurer proved mailing, 1 Provider proved mailing, 2 Provider failed to prove, 1 Triable issue on mailing)This decision
20052010201520202025
Insurer proved mailingInsurer failed to proveProvider proved mailingProvider failed to proveTriable issue on mailingMixed rulingsThis decisionCites it or cited by itCited or followed

Of the 1,400 decisions on this question in the Second Department courts and the Court of Appeals, 809 (this one included) are in the same category.

Cited in this decision

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

  • Manhattan Med. Imaging, P.C. v State Farm Mut. Auto. Ins. Co. (2008 NY Slip Op 51844(U))Staged accident and fraudulent incorporation defenses remain available despite an insurer's late denial.
  • Delta Diagnostic Radiology, P.C. v Chubb Group of Ins. (2007 NY Slip Op 27345) FollowedAn insurer may prove mailing by describing its standard procedure for properly addressing and mailing items.
  • St. Vincent’s Hosp. of Richmond v Government Empls. Ins. Co. (2008 NY Slip Op 04072)The insurer raised factual issues concerning a proper timely denial and its entitlement to deny the hospital's claim.
  • New York & Presbyt. Hosp. v Allstate Ins. Co. (2006 NY Slip Op 03558)The providers failed to establish mailing and receipt of the hospital bill asserted in their second cause of action.
  • Gentlecare Ambulatory Anesthesia Servs. v Geico Ins. Co. (2017 NY Slip Op 51518(U))An insurer need not state objective reasons for requesting EUOs to establish prima facie entitlement to summary judgment for nonappearance.
  • Throgs Neck Multicare, P.C. v Mercury Cas. Co. (2016 NY Slip Op 51081(U)) FollowedThe provider's treating doctor's affirmation raised a triable issue of medical necessity by sufficiently rebutting the insurer's IME report.
  • Pan Chiropractic, P.C. v Mercury Ins. Co. (2009 NY Slip Op 51495(U)) FollowedThe provider's conclusory disagreement with the insurer's supported peer review failed to raise a medical-necessity issue of fact.

Similar decisions

  • SB Chiropractic, P.C. v GEICO Ins. Co. (2022 NY Slip Op 50316(U))The insurer established timely denials, proper fee-schedule reductions and lack of medical necessity for post-IME treatment.
  • Tyorkin v Garrison Prop. & Cas. Ins. Co. (2016 NY Slip Op 50846(U))The insurer's failure to issue an NF-10 or show approval of an alternative precluded its medical-necessity defense.
  • Barakat P.T., P.C. v Progressive Ins. Co. (2021 NY Slip Op 50342(U))The insurer established a timely deductible denial even though it failed to substantiate its fee-schedule reduction.
  • Balance Art Acupuncture P.C. v MVAIC (2022 NY Slip Op 22061)MVAIC established proper payment at chiropractic acupuncture rates, and the provider failed to show that physician rates should apply.
  • Lenox Hill Radiology v New York Cent. Mut. Fire Ins. Co. (2008 NY Slip Op 28275)The insurer failed to prove its MRI fee reduction, and the provider failed to establish a business-record foundation for its claim form.
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