Dr. Todd Goldman, D.C., P.C. v Kemper Cas. Ins. Co., 2012 NY Slip Op 51296(U)(App. Term 2d Dept. 2012)
“However, as to plaintiff’s claim for $261.60 for services rendered on November 12, 2007, defendant failed to establish a lack of medical necessity for those services, which were rendered before the March 22, 2008 IME.”
Sounds so obvious… an IME is prospective. I think this is the first time I saw a case explicitly say this.
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