Key Takeaway
New York court ruling demonstrates how healthcare providers can fail to establish prima facie cases in no-fault insurance disputes by not proving timely payment or denial issues.
In New York’s no-fault insurance system, healthcare providers must meet specific procedural requirements when seeking summary judgment against insurance companies for unpaid claims. The burden of proof lies with the plaintiff to establish a prima facie case - meaning they must present evidence that, if accepted as true, would support their claim. This involves demonstrating either that the insurer failed to pay or deny the claim within the statutory 30-day period, or that any denial issued was legally deficient.
The Compas Med. decision from the Appellate Term illustrates how providers can stumble at this initial hurdle. Understanding these prima facie requirements is crucial for both healthcare providers and insurance companies navigating no-fault disputes, as failure to meet this threshold will result in dismissal regardless of the underlying merits of the case.
Jason Tenenbaum’s Analysis:
Compas Med., P.C. v Geico Ins. Co., 2014 NY Slip Op 51259(U)(App. Term 2d Dept, 2014)
Senor Jean Claude could not make a prima facie case on motion:
“Plaintiff’s moving papers failed to establish either that defendant had failed to pay or deny the claim within the requisite 30-day period (see Viviane Etienne Med. Care, P.C. v Country-Wide Ins. Co., 114 AD3d 33 ), or that defendant had issued a timely denial of claim that was conclusory, vague or without merit as a matter of law (see Insurance Law § 5106 ; Westchester Med. Ctr. v Nationwide Mut. Ins. Co., 78 AD3d 1168 ). Thus, plaintiff failed to establish its entitlement to summary judgment, and its motion for summary judgment was properly denied.”
The remainder of the opinion involves Defendant not proving its defenses prima facie
Key Takeaway
This case demonstrates that healthcare providers cannot simply file a motion for summary judgment without proper documentation. They must affirmatively prove either that the insurer missed the 30-day deadline or that any denial issued was legally deficient. As seen in other similar cases, inadequate moving papers will result in denial of the motion, regardless of whether the denial itself was proper.
Legal Update (February 2026): Since this 2014 post, Insurance Law § 5106 and related no-fault procedural requirements may have been subject to regulatory amendments, particularly regarding prima facie case standards, statutory timeframes for claim processing, and documentation requirements for summary judgment motions. Practitioners should verify current provisions in the Insurance Law and applicable regulations when establishing prima facie cases in no-fault disputes.
