Key Takeaway
New York court confirms that resubmitting the same no-fault insurance claim does not restart the 30-day payment deadline, rejecting a common provider strategy.
Healthcare providers occasionally attempt to reset statutory deadlines by resubmitting identical no-fault insurance claims, hoping to trigger a new 30-day period for insurers to pay or deny coverage. This strategy stems from New York’s no-fault law requirements that insurers must act within 30 days of receiving a claim. However, as demonstrated in a 2014 Appellate Term decision, this approach fundamentally misunderstands how the law operates.
The case of Westchester Medical Center v A Central Insurance Co. illustrates why resubmission tactics fail and why the original receipt date governs all subsequent deadlines. Understanding this principle is crucial for both healthcare providers seeking reimbursement and insurers managing their claims obligations under New York’s no-fault insurance regulations.
Jason Tenenbaum’s Analysis:
Westchester Med. Ctr. v A Cent. Ins. Co., 2014 NY Slip Op 50347(U)(App. Term 2d Dept. 2014)
“Defendant established, through the affidavit of its no-fault litigation examiner, that it had first received plaintiff’s hospital claim form on May 9, 2011. Defendant further indicated that it had received copies of the same hospital bill on May 25 and July 18, 2011.”
…
“Contrary to plaintiff’s contention, the 30-day period in which to pay or deny a claim did not run anew as the result of plaintiff’s resubmission of the claim” (see New York & Presbyt. Hosp. v AIU Ins. Co., 20 AD3d 515, 516 ; Hospital for Joint Diseases v Allstate Ins. Co., 5 AD3d 441, 442 )”
Back to 2005 again with the plaintiff saying that the additional verification requests are untimely due to the resubmission not being addressed. It lost 10 years ago and it lost again.
Key Takeaway
Resubmitting identical no-fault claims does not restart the 30-day statutory deadline for insurers to pay or deny coverage. Courts consistently hold that the original receipt date governs, regardless of subsequent resubmissions of the same documentation. This well-established precedent prevents providers from manipulating statutory deadlines through repetitive claim submissions.
