Key Takeaway
Renelique v Allstate: the 2017 CPT 20553 fee-proof ruling, the unpreserved 99203 argument and the limits of its comparison to Alleviation.
This article is part of our ongoing fee schedule coverage, with 118 published articles analyzing fee schedule 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.
Renelique upheld payment proof for code 20553. Its brief reference to Alleviation leaves Jason’s question about the applicable schedule version unanswered.
Historical note: Renelique does not identify its service dates or the schedule amendment Jason wondered about; the 35th amendment to Regulation 83 supplies a later October 2020 service-date boundary, not a retroactive explanation of this ruling.
Last reviewed: September 2026. Original publication date retained.
What the comparison does—and does not—show
Renelique v Allstate, 2017 NY Slip Op 51141(U) affirmed dismissal after reargument. The insurer demonstrated proper application of the workers’ compensation fee schedule to the 20553 services, and the provider did not rebut its proof. A separate argument concerning code 99203 was raised too late, for the first time on appeal.
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The opinion refers comparatively to Alleviation v State Farm (2015). It does not say that manipulation was required, identify a revised schedule or explain a change in the code’s by-report status. Those details should not be supplied from the citation signal alone.
Keep the two steps separate: the insurer first needs adequate proof of its calculation; the provider then needs evidence responsive to that showing. The original note’s uncertainty is worth preserving, rather than rewriting it as a fact established by the court.
Historical commentary from the archive
Jason expressly left the schedule-version question open. The quoted inference must not be converted into a finding about manipulation or a particular amendment:
I am unsure if this is pre or post FS amendment to code 20553. The c.f. citation is interesting, if it is presupposes that the older version of 20553 required manipulation to achieve the desired result.
Connect to the Encyclopedia
- Fee-schedule defense hub: cases, proof and later developments
- Gutierrez: Ground Rules 3 and 5 in the 20553 dispute
- Compas Medical: payment proof versus a suspected code substitution
- Jason’s G0283 note: attended and unattended coding in context
- Bronx Acupuncture: by-report verification and the motion result
For review of a particular no-fault billing dispute, contact our office.
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
Fee Schedule Issues in No-Fault Insurance
The New York no-fault fee schedule establishes the maximum reimbursement rates for medical treatment provided to injured motorists. Disputes over fee schedule calculations, coding, usual and customary charges, and the applicability of workers compensation fee schedules to no-fault claims are common. These articles analyze fee schedule regulations, court decisions on reimbursement disputes, and the practical challenges providers face in obtaining appropriate payment under the no-fault system.
118 published articles in Fee Schedule
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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.
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