Key Takeaway
Court ruling confirms NF-3 forms trigger 15-day IME request deadline, and patient no-shows at two scheduled exams justify insurance coverage disclaimer.
Understanding the NF-3 Form’s Role in No-Fault Insurance Claims
In New York’s no-fault insurance system, the NF-3 form serves as the cornerstone document that triggers critical procedural deadlines for insurance companies. This medical provider claim form not only requests reimbursement for treatment but also starts the clock ticking on an insurer’s right to conduct an Independent Medical Examination (IME). When patients fail to appear for properly scheduled IMEs, insurers gain powerful grounds to disclaim coverage entirely.
The recent Unitrin Direct Ins. Co. v Beckles decision illustrates how courts apply these procedural requirements in practice. Understanding this ruling is essential for both medical providers submitting claims and patients navigating the New York No-Fault Insurance Law system.
Jason Tenenbaum’s Analysis:
Unitrin Direct Ins. Co. v Beckles, 2020 NY Slip Op 06974 (1st Dept. 2020)
“Where, as here, the insurer submits evidence of a medical provider claim (NF-3), the timely request for an independent medical examination (IME) of the injured claimant within 15 days of the receipt of that claim, and the injured claimant is a no-show at two duly noticed IMEs, the basis for disclaimer of coverage is established, as a matter of law, and summary judgment is properly awarded to the insurer with respect to further coverage obligations and reimbursement of outstanding medical bills with respect to all treating providers (see Kemper Independence Ins. Co. v Adelaida Physical Therapy, P.C., 147 AD3d 437 ; National Liab. & Fire Ins. Co. v Tam Med. Supply Corp., 131 AD3d 851 ). “
Key Takeaway
This decision establishes a clear three-step process for insurers to disclaim coverage: receive an NF-3 claim, request an IME within 15 days, and document that the patient failed to appear at two properly noticed examinations. When these elements are proven, courts will grant summary judgment as a matter of law, protecting insurers from further payment obligations. The ruling reinforces that IME no-shows carry serious consequences for patients’ continued coverage.
