Another no-fault physician commits insurance fraud

The New York no-fault insurance system relies heavily on accurate medical reporting to function properly. When healthcare providers submit fraudulent documentation, it undermines the entire system and can result in serious criminal consequences. The case of People v Palmeri demonstrates how courts handle physicians who deliberately falsify required insurance forms.

No-fault C-4 forms are critical documents that medical providers must complete accurately when treating patients injured in motor vehicle accidents. These forms require physicians to assess whether a patient is totally disabled or capable of working — determinations that directly impact insurance benefits and coverage decisions under New York No-Fault Insurance Law.

Jason Tenenbaum’s Analysis:

People v Palmeri (Michael), 2012 NY Slip Op 22040 (App. Term 2d Dept. 2012)

It has just been an awful few months for the plaintiffs bar out there. First, many defacto owners of certain supply companies take guilty pleas, forfeit millions of dollars and end up with non-parolable 3-5 year sentences. Second, the feds in what appears to be the type of investigation known to stopping the Italian Mafia sends a well-deserved shock wave through our legal community. Now, a surgeon’s conviction for insurance fraud has been sustained. Just so you know, I am a month late on this one.

“The testimonies of the People’s witnesses appear truthful on their face, they are internally consistent as to material fact, and established that defendant knew, when he filled out the C-4 forms, that his patient was “working” within the meaning of question 7 on the form, and not “totally disabled” within the meaning of question 8 on the form. In so falsifying the C-4 forms, and filing said forms with the Board, defendant offered false instruments for filing in the second degree and committed insurance fraud in the fifth degree and petit larceny.”

Key Takeaway

The Palmeri case highlights the serious consequences medical providers face when they knowingly submit false information on no-fault insurance forms. Courts will uphold fraud convictions when witness testimony consistently demonstrates that a physician deliberately misrepresented a patient’s work capacity, emphasizing that knowledge is quite a broad term in insurance fraud prosecutions.

Legal Update (February 2026): Since this post’s publication, New York’s no-fault insurance regulations, fraud investigation procedures, and penalty structures for healthcare provider violations may have undergone significant amendments. Practitioners should verify current Insurance Law provisions, updated C-4 form requirements, and any revised fraud enforcement protocols that may affect liability and penalties for medical providers in the no-fault system.