Why Trust This Analysis
This article is part of our ongoing additional verification coverage, with 92 published articles analyzing additional verification issues across New York State. Attorney Jason Tenenbaum brings 24+ years of hands-on experience to this analysis, drawing from his work on more than 1,000 appeals, over 100,000 no-fault cases, and recovery of over $100 million for clients throughout Nassau County, Suffolk County, Queens, Brooklyn, Manhattan, and the Bronx. For personalized legal advice about how these principles apply to your specific situation, contact our Long Island office at (516) 750-0595 for a free consultation.
Pattern of Verification Receipt Disputes in No-Fault Insurance Cases
The New York no-fault insurance system requires insurance companies to pay legitimate medical claims promptly, but they can request additional verification when claims appear questionable. However, a troubling pattern has emerged in recent appellate cases where insurance carriers consistently claim to have received verification requests that healthcare providers insist they never sent.
This issue represents a significant challenge in New York No-Fault Insurance Law, where the burden of proof regarding verification receipt can determine whether a claim gets paid or denied. The stakes are particularly high given the 120-day rule and fee schedule requirements that govern these transactions.
Jason Tenenbaum’s Analysis:
TAM Med. Supply Corp. v National Liab. & Fire Ins. Co., 2016 NY Slip Op 51532(U)(App. Term 2d Dept. 2016)
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TAM Med. Supply Corp. v National Liab. & Fire Ins. Co.. , 2016 NY Slip Op 51533(U)(App. Term 2d Dept. 2016)
Renelique v American Tr. Ins. Co., 2016 NY Slip Op 51495(U)(App. Term 2d Dept. 2016)
Mollo Chiropractic, PLLC v Farmington Cas. Co., 2016 NY Slip Op 51496(U)(App. Term 2d Dept. 2016)
TAM Med. Supply Corp. v American Tr. Ins. Co., 2016 NY Slip Op 51505(U)(App. Term 2d Dept. 2016)
TAM Med. Supply Corp. v National Liab. & Fire Ins. Co., 2016 NY Slip Op 51506(U)(App. Term 2d Dept. 2016)
TAM Med. Supply Corp. v American Tr. Ins. Co., 2016 NY Slip Op 51507(U)(App. Term 2d Dept. 2016)
TAM Med. Supply Corp. v American Tr. Ins. Co., 2016 NY Slip Op 51513(U)(App. Term 2d Dept. 2016)
LMS Acupuncture, P.C. v Nationwide Ins., 2016 NY Slip Op 51537(U)(App. Term 2d Dept. 2016)
(and 3 others)
What are the odds off all these insurance carriers stating verification was received and that not being the case? Just wondering.
Key Takeaway
The frequency of these verification receipt disputes raises important questions about documentation and communication protocols in no-fault insurance claims processing. Healthcare providers should maintain detailed records of all correspondence and consider implementing tracking systems to address these additional verification non-receipt challenges effectively.
Legal Update (February 2026): Since this post’s 2016 publication, New York’s no-fault fee schedules have been subject to multiple regulatory updates and amendments. Additionally, procedural requirements for verification requests and receipt documentation may have been modified through regulatory changes or updated Department of Financial Services guidelines. Practitioners should verify current fee schedule provisions and verification procedures when handling these disputes.
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Legal Context
Why This Matters for Your Case
New York law is among the most complex and nuanced in the country, with distinct procedural rules, substantive doctrines, and court systems that differ significantly from other jurisdictions. The Civil Practice Law and Rules (CPLR) governs every stage of civil litigation, from service of process through trial and appeal. The Appellate Division, Appellate Term, and Court of Appeals create a rich and ever-evolving body of case law that practitioners must follow.
Attorney Jason Tenenbaum has practiced across these areas for over 24 years, writing more than 1,000 appellate briefs and publishing over 2,353 legal articles that attorneys and clients rely on for guidance. The analysis in this article reflects real courtroom experience — from motion practice in Civil Court and Supreme Court to oral arguments before the Appellate Division — and a deep understanding of how New York courts actually apply the law in practice.
About This Topic
Additional Verification in No-Fault Claims
Under New York's no-fault regulations, insurers may request additional verification of a claim within specified time limits. The timeliness, scope, and reasonableness of verification requests — and the consequences of a claimant's failure to respond — are among the most litigated issues in no-fault practice. These articles examine the regulatory framework for verification requests, court decisions on compliance, and the interplay between verification delays and claim determination deadlines.
92 published articles in Additional Verification
Keep Reading
More Additional Verification Analysis
No Denial Required When Provider Fails to Respond to Verification Within 120 Days
Chapa v MVAIC rejected a 150-day denial deadline, not the need to prove a verification defense. Read the 2026 decision and the historical case directory.
Feb 25, 2026
120-day rule and Fee Schedule
New York court ruling demonstrates how healthcare providers can lose no-fault claims due to verification failures and fee schedule violations in insurance disputes.
Feb 1, 2020
Delay letters v. verification requests
New York court clarifies that generic delay letters don't toll statutory payment deadlines—only specific verification requests can extend an insurer's time to pay or deny claims.
Nov 28, 2015
Evidence insufficient to prove that provider complied with verification request
Pomona v Praetorian: why a third-party biller's affidavit failed to prove a verification response, without requiring an eyewitness to every mailing.
Nov 3, 2013
The EIP does NOT need to be notified when the carrier is seeking verification from a provider of medical services
Triangle R v Clarendon: misaddressed copies to the injured person did not invalidate verification requests properly directed to the medical provider.
Dec 18, 2010
Verification, again
New Horizon v Travelers: a requested informed-consent form was missing from the verification record, defeating the provider's assertion of full compliance.
Mar 20, 2019Was this article helpful?
Disclaimer: This article is published by the Law Office of Jason Tenenbaum, P.C. for informational and educational purposes only. It does not constitute legal advice, and no attorney-client relationship is formed by reading this content. The legal principles discussed may not apply to your specific situation, and the law may have changed since this article was last updated.
New York law varies by jurisdiction — court decisions in one Appellate Division department may not be followed in another, and local court rules in Nassau County Supreme Court differ from those in Suffolk County Supreme Court, Kings County Civil Court, or Queens County Supreme Court. The Appellate Division, Second Department (which covers Long Island, Brooklyn, Queens, and Staten Island) and the Appellate Term (which hears appeals from lower courts) each have distinct procedural requirements and precedents that affect litigation strategy.
If you need legal help with a additional verification matter, contact our office at (516) 750-0595 for a free consultation. We serve clients throughout Long Island (Huntington, Babylon, Islip, Brookhaven, Smithtown, Riverhead, Southampton, East Hampton), Nassau County (Hempstead, Garden City, Mineola, Great Neck, Manhasset, Freeport, Long Beach, Rockville Centre, Valley Stream, Westbury, Hicksville, Massapequa), Suffolk County (Hauppauge, Deer Park, Bay Shore, Central Islip, Patchogue, Brentwood), Queens, Brooklyn, Manhattan, the Bronx, Staten Island, and Westchester County. Prior results do not guarantee a similar outcome.
