August 4, 2011
Neomy Med., P.C. v GEICO Ins. Co. (2011 NY Slip Op 51532(U))
https://www.beynensonlaw.com/case-law/neomy-med-p-c-v-geico-ins-co-2011-ny-slip-op-51532u/
- Decided
- August 4, 2011
- Citation
- 2011 NY Slip Op 51532(U) · 32 Misc 3d 137(A)
- Posture
- Summary judgment
- Outcome
- Insurer prevailed
- Later treatment
- Followed in 2 later decisions (see Cited by)
- Legal questions
- Lack of medical necessity · Proof of mailing (see the maps)
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 Neomy Med., P.C. v GEICO Ins. Co. (2011 NY Slip Op 51532(U))
| Neomy Med., P.C. v GEICO Ins. Co. |
| 2011 NY Slip Op 51532(U) [32 Misc 3d 137(A)] |
| Decided on August 4, 2011 |
| 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| This opinion is uncorrected and will not be published in the printed Official Reports.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, 11th and 13th JUDICIAL DISTRICTS
PRESENT: : WESTON, J.P., PESCE and RIOS, JJ
2010-658 K C.
against
GEICO Insurance Company, Appellant.
Appeal from an order of the Civil Court of the City of New York, Kings County (Peter Paul Sweeney, J.), entered September 30, 2009. The order, insofar as appealed from, denied defendant’s cross motion for summary judgment dismissing the complaint.
ORDERED that the order, insofar as appealed from, is reversed, without costs, and defendant’s cross motion for summary judgment dismissing the complaint is granted.
In this action by a provider to recover assigned first-party no-fault benefits, plaintiff moved
for summary judgment, and defendant cross-moved for summary
judgment dismissing the complaint. The Civil Court held that there is an issue of fact with
respect to the medical necessity of the services rendered to plaintiff’s assignor because defendant
had not annexed the medical records upon which the peer review relied and defendant had failed
to establish a foundation for the admission of the records. Defendant appeals from so much of the
order as denied its cross motion for summary judgment dismissing the complaint.
Defendant established that it had timely mailed the denial of claim form (see St. Vincent’s Hosp. of Richmond v Government Empls. Ins. Co., 50 AD3d 1123 [2008]; Delta Diagnostic Radiology, P.C. v Chubb Group of Ins., 17 Misc 3d 16 [App Term, 2d & 11th Jud Dists 2007]), which denied the claim at issue on the ground of lack of medical necessity. In support of its cross motion for summary judgment, defendant also submitted, among other things, a peer review report, which set forth a factual basis and medical rationale for the conclusion that there was a lack of medical necessity for the services at issue. Contrary to the determination of the Civil Court, there was no need for defendant to annex the medical records examined by the peer review doctor (cf. Matter of State of New York v Wilkes, 77 AD3d 1451 [2010]). Furthermore, [*2]since the purpose of the peer review report submitted by defendant was not to attempt to prove that plaintiff’s assignor was injured as documented in his medical records, or that she was treated as set forth in those records, but to establish that, assuming the facts set forth therein were true, the treatment allegedly provided by plaintiff was not medically necessary, defendant was not required to demonstrate that the records fell within an exception to the rule against hearsay (see id.; Urban Radiology, P.C. v Tri-State Consumer Ins. Co., 27 Misc 3d 140[A], 2010 NY Slip Op 50987[U] [App Term, 2d, 11th & 13th Jud Dists 2010]). Consequently, defendant established its prima facie entitlement to summary judgment (see Delta Diagnostic Radiology, P.C. v Integon Natl. Ins. Co., 24 Misc 3d 136[A], 2009 NY Slip Op 51502[U] [App Term, 2d, 11th & 13th Jud Dists 2009]; Delta Diagnostic Radiology, P.C. v American Tr. Ins. Co., 18 Misc 3d 128[A], 2007 NY Slip Op 52455[U] [App Term, 2d & 11th Jud Dists 2007]; A. Khodadadi Radiology, P.C. v NY Cent. Mut. Fire Ins. Co., 16 Misc 3d 131[A], 2007 NY Slip Op 51342[U] [App Term, 2d & 11th Jud Dists 2007]). Defendant’s showing that the services rendered to plaintiff’s assignor were not medically necessary was unrebutted by plaintiff. Accordingly, defendant’s cross motion for summary judgment dismissing the complaint should have been granted.
Weston, J.P., and Pesce, J., concur.
Rios, J., concurs in a separate memorandum.
Rios, J., concurs in the following memorandum:
Contrary to the finding of the majority, in my opinion, the affidavit of defendant’s representative failed to describe on personal knowledge the mailing procedure employed at GEICO by the mailroom employees.
The affidavit alleges in conclusory terms that the envelopes containing the denials are placed
in a mail bin for collection by mailroom employees and that they are:
“routinely collected by GEICO’s mail department personnel at least twice daily and
delivered to the GEICO mailroom, located within the building at the Woodbury location. These
envelopes are postmarked with that day’s date by a GEICO mailroom employee. Proper postage
due is also affixed by GEICO’s mail personnel through a United States Post Office authorized
postage machine. On that same day, a GEICO mailroom employee brings these postmarked,
postage paid envelopes to the United States Post Office, Woodbury location, at 217 Woodbury
Road, Woodbury, New York, 11797. This GEICO employee then personally relinquishes these
envelopes to a United States Postal Service employee.”
In my view, the affidavit fails to establish a procedure sufficient to demonstrate that the mailing is forwarded to the claimant, especially where no certificate of bulk mailing from the postal service is offered (see Residential Holding Corp. v Scottsdale Ins. Co.,286 AD2d 679 [2001]; Hospital For Joint Diseases v Nationwide Mut. Ins. Co., 284 AD2d 374 [2001]).
Notwithstanding the apparent flaw in defendant’s proof, the majority points to the holding in
St. Vincent’s Hosp. of Richmond v
Government Employees Ins. Co. (50 AD3d 1123 [2008]), [*3]which held that a similar affidavit established a general office
procedure sufficient to ensure that documents were properly addressed and mailed. In St.
Vincent’s, the appellate court credited a statement by the insurer’s representative that
“the contents of this mail pick-up bin are collected by GEICO’s mail department personnel
. . . Within 48 hours of its arrival in the GEICO mail room, the mail is delivered to the local
United States Postal Service location and mailed.”
Accordingly, I am constrained to concur with my colleagues in their determination.
Decision Date: August 04, 2011
Legal questions (2)
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 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 peer review established lack of medical necessity without annexing the reviewed records, which were not offered for their truth, and the provider failed to rebut it.
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.
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 insurer established that it timely mailed the denial of claim form under its standard office practices, a showing the provider did not defeat.
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.
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.
- 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.
- Urban Radiology, P.C. v Tri-State Consumer Ins. Co. (2010 NY Slip Op 50987(U)) FollowedThe insurer established premature claims for unanswered verification and lack of medical necessity for the remaining claims.
- Delta Diagnostic Radiology, P.C. v Integon Natl. Ins. Co. (2009 NY Slip Op 51502(U)) FollowedThe insurer's examining physician supplied an unrebutted factual basis and medical rationale that the billed MRI was unnecessary.
- Delta Diagnostic Radiology, P.C. v American Tr. Ins. Co. (2007 NY Slip Op 52455(U)) FollowedThe insurer's unrebutted peer review established that the provider's MRIs lacked medical necessity.
- A Khodadadi Radiology, P.C. v NY Cent. Mut. Fire Ins. Co. (2007 NY Slip Op 51342(U)) FollowedThe insurer's unrebutted peer review established that the provider's MRIs lacked medical necessity.
Cited by
A label shows how the later decision treated this one.
- Total Equip., LLC v Praetorian Ins. Co. (2011 NY Slip Op 21398) FollowedThe provider established a need for discovery of the no-fault file before opposing the insurer's medical-necessity motion.
- Comfort Supply, Inc. v Progressive Northeastern Ins. Co. (2011 NY Slip Op 52289(U)) FollowedA peer review report is not inadmissible merely because the insurer omits the underlying medical records considered by the reviewer.
Similar decisions
- Manhattan Med. Imaging, P.C. v GEICO Ins. Co. (2010 NY Slip Op 51737(U))The insurer's timely denial and supported peer review raised a triable issue of medical necessity, defeating provider summary judgment.
- Bath Med. Supply, Inc. v GEICO Ins. Co. (2010 NY Slip Op 52316(U))The insurer's peer reviews established lack of medical necessity, and the provider failed to justify delaying summary judgment for discovery.
- Orthotic Surgical & Med. Supply, Inc. v GEICO Ins. Co. (2008 NY Slip Op 51540(U))The insurer's peer review failed to raise a medical-necessity issue because its facsimile signature lacked proof of the doctor's authorization.
- Contemp. Med. Diag. & Treatment, P.C. v Government Employees Ins. Co. (2005 NY Slip Op 50254(U))The insurer's conclusory office-practice affidavit failed to prove timely mailing of verification requests.
- Quality Health Prods. v Geico Gen. Ins. Co. (2011 NY Slip Op 52299(U))The insurer's peer review was admissible because its facsimile signature was placed by the reviewing doctor or at the doctor's direction.