Burke 2 Physical Therapy, P.C. v State Farm Mut. Auto. Ins. Co. PIP/BI Claims
The provider failed to raise a factual issue concerning compliance with verification requests within 120 days.
2026 NY Slip Op 26164
For New York no-fault healthcare providers
Tech Driven
New York No-Fault Collections
We represent medical practices, therapy practices, imaging centers, pharmacies and DME suppliers in collecting denied no-fault claims, at arbitration and in court, with our own billing software and data on how arbitrators, insurers and courts decide.
The No-Fault Claim, Step by Step
Every deadline in a New York no-fault claim, from the accident to arbitration and court: what the insurer must do and when, what a missed deadline costs each side, and the regulation and decisions behind each rule.
- The 30-day rule, verification, IMEs and EUOs, no-shows and the department splits
- A calculator that works out the deadlines for your claim's dates
- Every rule linked to 11 NYCRR Part 65 and the leading cases
Who We Represent
Medical practicesPhysicians, orthopedics, pain management, surgery centers
Therapy practicesPhysical therapy, chiropractic, acupuncture
Imaging and diagnosticsMRI, radiology, diagnostic testing
Pharmacies and DME suppliersPharmacies, medical equipment and supply companies
What We Do for Providers
Arbitration of denied claims
We file and argue denied no-fault claims in arbitration, prepared with data on the arbitrator and the insurer.
Court collections
Actions in Civil Court on denied claims, and appeals.
Billing support
Billing and claim submission through our in-house software, with procedures built on analysis of past collection outcomes.
EUO and RICO defense
Representation at Examinations Under Oath requested by insurers, and in civil RICO and fraud litigation.
Know Where Your Claims Stand
Our reporting is built from New York no-fault arbitration awards and updated every month.
Provider Report
Choose a provider and see their arbitration results month by month:
- cases won, total cases decided, principal awarded and approximate interest
- awards and win rate per month over the past 36 months
- a breakdown by attorney, for the past month and the past 36 months
- a breakdown by insurance company, with win rates against each
Arbitrator ScorecardEvery arbitrator active in the last 30 days: awards written and the share awarded, denied or dismissed.
Arbitrator / Carrier DataAwards, amounts awarded and outcome rates per arbitrator and insurer, month by month.
Provider / Carrier DataThe same figures per provider and insurer.
Provider / Attorney DataThe same figures per provider and the provider’s attorney.
Which insurers end up in arbitration
Share of New York no-fault arbitration awards by insurer, per month. Denial rates and settlement habits differ between insurers, so this shows business trends rather than auto insurance market share. Daily award volume
Notable Recent Decisions
Recent rulings from the appellate and trial courts on no-fault claims, with whether the provider or the insurer prevailed.
October 2026 in no-fault law
- De novo actions. The Second Department held that dismissing an insurer's Insurance Law § 5106 (c) action for discovery noncompliance revived the dormant master arbitration award for confirmation (Bliss Acupuncture).
- Article 75 fees. The First Department held that denying vacatur required confirmation (CPLR 7511 (e)) and the provider was entitled to 11 NYCRR 65-4.10 (j) fees (Midland Pharm.); the Second Department remitted a fee award that stated no basis (Pfeffer).
- SUM trigger. The Second Department found SUM coverage not triggered where the tortfeasor's primary and umbrella limits exceeded the SUM policy's liability limits (Erie v Rodriguez).
- Late MVAIC claims. Citing Raffellini, the Appellate Term, First Department, held the trial court could not disregard claim time frames on policy grounds and found a four-month delay unjustified (Medical Imaging of Bronx).
Our summary of the month’s decisions, not the courts’ words.
Matter of Nostrand Drugs Rx, Inc. v Church Mut. Ins. Co.
The provider's petition to vacate a master arbitration award was denied because it showed no statutory ground for vacatur.
2026 NY Slip Op 05400
Matter of 563 Grand Med., P.C. v Country-Wide Ins. Co.
The provider's unreasonable arbitration delay required excluding September 10, 2003, through November 6, 2018, from statutory interest.
2026 NY Slip Op 04291