Key Takeaway
Court ruling shows unsworn, unsigned letters of medical necessity lack probative value in no-fault insurance disputes, emphasizing proper documentation requirements.
In New York no-fault insurance disputes, the quality and format of evidence can make or break a case. Healthcare providers seeking reimbursement from insurance companies must meet specific evidentiary standards when submitting documentation to support their claims. This is particularly crucial when it comes to establishing medical necessity—one of the fundamental requirements for coverage under New York No-Fault Insurance Law.
The Appellate Term’s decision in Innovative MR Imaging, P.C. v Praetorian Ins. Co. serves as a stark reminder that even substantively strong medical evidence can be worthless if it fails to meet basic procedural requirements. When insurance companies challenge the medical necessity of treatment through summary judgment motions, healthcare providers must respond with properly authenticated documentation. The court’s analysis demonstrates how technical deficiencies in evidence submission can undermine an otherwise valid claim for reimbursement.
This case highlights the intersection between evidence law and no-fault insurance litigation, where medical necessity determinations often hinge on the admissibility and weight given to supporting documentation.
Jason Tenenbaum’s Analysis:
Innovative MR Imaging, P.C. v Praetorian Ins. Co., 2015 NY Slip Op 51402(U)(App. Term 1st Dept. 2015)
“In opposition to defendant’s motion, plaintiff submitted two letters of medical necessity. However, as neither letter of medical necessity was sworn or even signed, they were of no probative value (see Rivers v Birnbaum, 102 AD3d 26, 45 ). As a result, defendant’s prima facie showing that the services were not medically necessary was unrebutted by plaintiff.”
Key Takeaway
Healthcare providers must ensure that letters of medical necessity are properly executed—at minimum signed, and preferably sworn—to have any evidentiary value in court. Unsigned and unsworn documents, regardless of their content, cannot rebut an insurance company’s challenge to medical necessity. This procedural requirement underscores the importance of proper documentation practices in no-fault insurance litigation, where business records and medical reports must meet established authentication standards.
