Key Takeaway
Court rules acupuncturists can bill for initial visits under code 99202, but leaves open question about reimbursement rates compared to chiropractors.
Court Confirms Acupuncturists Can Bill for Initial Visits
A significant appellate ruling has clarified an important billing question for acupuncture providers working with no-fault insurance cases. The decision addresses whether acupuncturists can properly bill for initial evaluation visits and what this means for reimbursement rates under New York’s no-fault insurance system.
This case emerges from the complex landscape of medical billing codes and fee schedules that govern how healthcare providers are compensated for treating auto accident victims. The ruling specifically examined billing practices for acupuncture services, an area where providers have faced ongoing challenges regarding proper coding and reimbursement rates. Understanding these nuances is crucial for both providers seeking fair compensation and insurers managing claims costs.
Jason Tenenbaum’s Analysis:
Flushing Traditional Acupuncture, P.C. v Geico Ins. Co., 2013 NY Slip Op 51538(U)(App. Term 2d Dept. 2013)
The court has now explicitly held that a medical provider is entitled to bill for an initial acupuncture visit.
“the Civil Court properly granted the branches of defendant’s cross motion seeking summary judgment dismissing so much of the complaint as sought to recover for those services. However, as defendant failed to address an “initial evaluation,” which had been billed under code 99202, defendant should not have been awarded summary judgment dismissing so much of the complaint as sought to recover the sum of $53.61 that was billed under that code.”
So the open question is whether an acupuncturist is entitled to the chiropractor rate for an initial visit and other rendered services?
I sense the answer is yes,
Key Takeaway
This ruling establishes that acupuncturists can properly bill for initial evaluation visits using code 99202, but leaves unresolved the critical question of reimbursement rates. The decision suggests that acupuncturists may be entitled to the same fee schedule rates as chiropractors, which could significantly impact billing practices and provider compensation in no-fault cases.
The implications extend beyond this specific case, as similar billing code questions arise with other treatment modalities covered under CPT codes like 97813 and 97814 for acupuncture services.
Legal Update (February 2026): Since this 2013 decision, New York’s no-fault fee schedules and billing codes have undergone multiple revisions, including updates to evaluation and management codes and acupuncture reimbursement rates. The regulatory framework governing initial visit billing and applicable fee schedules may have been substantially modified through Insurance Department amendments and statutory changes. Practitioners should verify current provisions in the most recent fee schedule regulations and consult updated billing guidelines before relying on the billing practices described in this post.
