Key Takeaway
Compas Medical's 2017 ruling upheld payment proof for code 64550; it did not identify a 97014 substitution. Jason's inference is kept in context.
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.
Compas upheld the insurer’s payment proof for CPT 64550. The opinion never identifies a substitution to 97014; that was Jason’s inference.
Historical note: Compas resolves the proof submitted on particular claims, not a universal code-conversion rule; the 35th amendment’s October 2020 service-date boundary is a later schedule change to check independently.
Last reviewed: September 2026. Original publication date retained.
What Compas actually reports
In Compas Medical v 21st Century, 2017 NY Slip Op 51228(U), the Appellate Term left dismissal of the first and fifth causes of action intact because the insurer’s payment proof was unrebutted. It restored the fourth cause because the insurer had not established the necessary denial timing; the provider did not win judgment on that claim either.
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The opinion does not say that the insurer substituted 97014, specify the clinical procedure or set out the calculation behind the payment. The prior page’s account of nerve injections and its imagined medical-record dispute went beyond the decision.
The CMS historical code table identifies 64550 with skin-surface neurostimulator electrodes, not nerve injections. That coding reference does not itself establish New York reimbursement or authorize a substitution. Review the bill, payment explanation and underlying proof rather than treating the inferred conversion as a rule.
Historical commentary from the archive
Jason’s original comment inferred the substituted code and proof. The reported opinion confirms sufficient payment proof, but does not identify a conversion from 64550 to 97014:
I am sure the carrier repriced 64550 to 97014. The Court held, with an affidavit, the repricing was proper.
Connect to the Encyclopedia
- Fee-schedule defense hub: cases, proof and later developments
- Gutierrez: Ground Rules 3 and 5 in the 20553 dispute
- Renelique: payment proof for 20553
- 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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