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No Fault Attorney For Medical Providers

Home » New York No-Fault Collections Lawyer for Medical Providers

No-Fault Collections for Doctors, Hospitals, Facilities, and Healthcare Providers

New York medical providers often receive payment directly through an Assignment of Benefits, allowing the provider to stand in the shoes of the injured patient and pursue reimbursement from the no-fault carrier. New York DFS guidance for no-fault arbitration states that a medical provider filing as an assignee must submit a completed Assignment of Benefits form signed by the injured party.

Our no-fault collections practice is built for providers that are tired of unpaid receivables, confusing carrier denials, repetitive claim delays, and underpayments that quietly reduce practice revenue. We handle:

  • Unpaid NF-3 and provider bills
  • NF-10 denials
  • Partial payments and underpayments
  • Fee schedule reductions
  • IME cut-off denials
  • Peer review denials
  • EUO no-show denials
  • Verification delays and repeated verification requests
  • Medical necessity disputes
  • Causation disputes
  • Policy exhaustion disputes
  • Priority of coverage disputes
  • Workers’ compensation and work-related accident issues
  • MVAIC, uninsured vehicle, and hit-and-run issues
  • Declaratory judgment actions filed by insurance carriers
  • Arbitration and litigation of denied medical bills
  • Settlement negotiations with insurers
  • Follow-up collection after arbitration awards, judgments, or settlements

We Review the Denial, Not Just the Balance

A no-fault denial is not always valid just because the carrier issued one. We examine whether the denial was timely, whether the insurer properly requested verification, whether the basis for denial is legally sufficient, whether the defense was preserved, whether the defense is precludable, and whether the evidence supports payment.

We Build Strong Claim Files

A strong no-fault collections case starts with documentation. We help organize and analyze:

Why No-Fault Collections Matter for Healthcare Providers

No-fault insurance was designed to provide payment for certain accident-related economic losses regardless of who caused the accident. For healthcare providers, that system can create an important source of payment for treatment provided to injured patients. But the system only works when carriers properly evaluate claims and pay valid bills.

Unfortunately, providers often encounter denials and delays after treatment has already been rendered. The patient may have assigned benefits to the provider, the provider may have submitted bills and medical records, and the insurer may still refuse to pay. This is where healthcare provider no-fault collections become essential.

A provider may need legal help when the carrier claims that treatment was not medically necessary, that the patient failed to appear for an IME, that verification remains outstanding, that the bill exceeds the fee schedule, that the claim was submitted late, that the treatment was unrelated to the accident, that coverage was exhausted, or that the provider failed to establish a prima facie entitlement to payment.

A no-fault medical collections attorney helps providers identify which claims are worth pursuing, which documents are needed, which defenses may apply, and which procedural steps should be taken. A medical provider no-fault attorney can also help a practice implement better billing, documentation, and collections procedures so future claims are stronger from the beginning.

For providers carrying hundreds or thousands of unpaid no-fault bills, legal collections are not merely about one disputed invoice. They are about cash flow, compliance, documentation, revenue cycle management, and preserving the value of services already provided.

Who Needs a No-Fault Collections Lawyer?

Many different businesses and professionals submit no-fault claims. A comprehensive provider-side no-fault practice may represent:

N

NF-3 forms

N

CMS-1500, HCFA, UB-04, and itemized bills

N

Assignment of Benefits forms

N

Proof of mailing

N

Medical reports

N

SOAP notes

N

Treatment plans

N

Prescriptions and referrals

N

Diagnostic reports

N

Prior awards or related litigation history

N

Operative reports

N

CPT, HCPCS, ICD-10, and modifier support

N

Fee schedule calculations

N

Verification responses

N

EUO and IME notices

N

Peer review and IME reports

N

NF-10 denials

N

EOBs and payment ledgers

N

Claim correspondence

We Pursue Payment Through Arbitration, Litigation, and Settlement

New York DFS directs that no-fault arbitration requests must be filed with the American Arbitration Association, and a provider may arbitrate a denial by completing the NF-10 back page or AAA Form AR1 with supporting documentation. We evaluate whether arbitration, litigation, settlement, or another collection route is the best strategy for each claim.

We Understand Carrier Delay Tactics

Carriers often delay payment by requesting repeated verification, claiming missing documents, issuing broad peer reviews, scheduling EUOs, invoking IME cutoffs, asserting policy exhaustion, or using coverage investigations to slow down provider receivables. We understand these patterns and prepare files to overcome them.

Common New York No-Fault Denial Reasons We Handle

Insurance companies deny no-fault claims for many reasons. Some denials involve technical billing issues. Others involve medical necessity. Some involve no coverage or fraud allegations. Some are valid. Many are not. Below is a comprehensive list of common denial reasons we review, challenge, arbitrate, and litigate.

1. Timeliness and Claim Submission Denials

Carriers frequently deny claims by arguing that the injured person, provider, or assignee missed a no-fault deadline. New York DFS explains that Regulation 68 changed the key timeframes to 30 days for written notice of claim, 45 days for submission of healthcare bills, and 90 days for lost wage claims. DFS Office of General Counsel guidance also states that healthcare providers generally must submit medical proof of claim no later than 45 days after services are rendered.

We handle denials alleging:

  • Late NF-2 or late written notice of accident
  • Late submission of medical bills
  • Late submission of hospital bills
  • Late submission of physical therapy bills
  • Late submission of chiropractic bills
  • Late submission of acupuncture bills
  • Late submission of MRI, CT, X-ray, or diagnostic testing bills
  • Late submission of DME or medical supply bills
  • Late proof of claim
  • Missing proof of claim
  • Incomplete proof of claim
  • Claim submitted to the wrong carrier
  • Claim submitted to the wrong claim office
  • Claim submitted without adequate accident information
  • Claim submitted without sufficient patient identification
  • Claim submitted without claim number or policy number
  • Untimely resubmission after rejection
  • Timeliness dispute caused by carrier misrouting or misidentification
  • Carrier claim that the bill was never received
  • Carrier claim that the bill was received after the 45-day deadline
  • Carrier claim that proof of mailing is insufficient
  • Carrier claim that the injured person failed to justify late notice
  • Carrier claim that treatment was not contemplated within the required timeframe
  • Carrier claim that provider billing was delayed without reasonable justification

2. 30-Day Pay-or-Deny Rule Disputes

No-fault carriers cannot simply hold a completed claim indefinitely. New York no-fault rules generally require the insurer to pay or deny benefits within 30 calendar days after receiving proof of claim, including properly requested verification. DFS guidance explains that no-fault benefits become overdue when they are not paid within the required period after the claimant supplies proof of the fact and amount of loss. DFS has also stated that denial timeliness is measured by the date the denial is mailed, not merely the date printed on the denial form.

We review whether:

  • The denial was mailed within 30 days
  • The carrier can prove timely mailing
  • The carrier improperly backdated the denial
  • The carrier failed to pay or deny the claim
  • The carrier issued an untimely NF-10
  • The carrier’s verification request properly tolled the 30-day period
  • The carrier denied before receiving all requested verification
  • The carrier failed to issue a proper denial for a partial payment
  • The denial preserved the specific defense being asserted
  • The carrier added new defenses after the 30-day period
  • The denial form is vague, generic, or unsupported
  • The carrier is precluded from raising late defenses
  • The carrier issued a payment without preserving its reduction theory
  • The carrier failed to explain the basis for nonpayment

3. Verification Request Denials

Insurance companies may request additional verification, but verification demands must follow no-fault rules. DFS guidance states that insurers may request additional verification within 15 business days of receiving prescribed verification forms and must follow up when requested verification has not been provided. DFS has also stated that an insurer may not unilaterally set its own arbitrary deadline and deny merely because the claimant failed to respond by that carrier-created deadline.

We handle verification-based denials involving:

  • Alleged failure to provide medical records
  • Alleged failure to provide SOAP notes
  • Alleged failure to provide diagnostic reports
  • Alleged failure to provide operative reports
  • Alleged failure to provide prescriptions or referrals
  • Alleged failure to provide prior medical records
  • Alleged failure to provide claim forms
  • Alleged failure to provide proof of mailing
  • Alleged failure to provide W-9, tax ID, or NPI information
  • Alleged failure to provide provider licensing documents
  • Alleged failure to provide invoices for DME or supplies
  • Alleged failure to provide proof of delivery for DME
  • Alleged failure to provide assignment of benefits
  • Alleged failure to provide employment or wage records
  • Alleged failure to provide accident reports
  • Alleged failure to provide patient statements
  • Alleged failure to respond to SIU requests
  • Alleged failure to provide prior claim or prior accident information
  • Alleged failure to provide attorney representation documents
  • Premature denials while verification was outstanding
  • Repeated verification requests seeking already-submitted documents
  • Overbroad verification requests
  • Verification requests unrelated to the bill at issue
  • Denials based on missing verification without proper follow-up
  • Denials where the carrier cannot prove the verification request was mailed

4. EUO Denials

An Examination Under Oath, or EUO, is a common carrier investigation tool. DFS guidance states that EUO requests must be based on objective standards and that EUOs must be scheduled at a time and place reasonably convenient to the applicant. DFS has also stated that when a party fails to attend a scheduled EUO, the carrier must give a second opportunity before issuing a denial based on nonattendance.

We represent providers facing denials based on:

  • Patient EUO no-show
  • Provider EUO no-show
  • Owner or principal EUO no-show
  • Treating provider EUO no-show
  • Alleged failure to appear for two EUOs
  • Defective EUO notices
  • EUO notices sent to the wrong address
  • EUO notices not sent to counsel
  • EUO notices sent without adequate time to appear
  • EUO scheduled at an unreasonable time or location
  • EUO demand not based on objective justification
  • EUO request issued too late
  • EUO follow-up issued too late
  • EUO denial issued too early
  • EUO denial applied to bills not properly subject to the request
  • EUO denial issued without proof of mailing
  • EUO denial where the provider or patient had a reasonable excuse
  • EUO denial where the carrier refused to reschedule reasonably
  • EUO denial raised as a global coverage defense
  • Declaratory judgment actions based on alleged EUO noncompliance
  • EUO demands used to investigate corporate structure, licensing, referrals, or ownership

5. IME Denials and IME Cutoffs

Carriers frequently deny treatment after an Independent Medical Examination, also called an IME or insurance medical examination. These denials often say that further treatment is not medically necessary, that the patient has reached maximum medical improvement, or that treatment after a cutoff date is unrelated to the accident.

We handle IME-based denials involving:

  • IME no-show
  • Alleged failure to attend two IMEs
  • Defective IME notices
  • IME notices sent to the wrong address
  • IME notices not sent to counsel
  • IME scheduled at an unreasonable time or location
  • IME report unsupported by the records
  • IME doctor outside the relevant specialty
  • IME report that fails to address the billed services
  • IME report that fails to address the injured person’s complaints
  • IME report based on incomplete records
  • IME report based on a limited or inaccurate history
  • IME cut-off applied to treatment before the cutoff date
  • IME cut-off applied to unrelated specialties
  • IME denial without timely NF-10
  • IME denial unsupported by objective findings
  • IME denial contradicted by treating provider records
  • IME denial based on conclusory language
  • IME denial based on maximum medical improvement
  • IME denial based on resolved sprain/strain
  • IME denial based on alleged lack of disability
  • IME denial based on alleged lack of ongoing need for physical therapy, chiropractic, acupuncture, pain management, diagnostic testing, surgery, DME, or prescriptions

DFS guidance recognizes that denials based on IMEs or peer reviews present medical fact disputes that may be resolved through no-fault arbitration or court.

6. Peer Review and Medical Necessity Denials

Peer review denials are among the most common reasons providers are not paid. The carrier hires a reviewing doctor or consultant who claims that the treatment was excessive, unnecessary, unrelated, experimental, duplicative, unsupported, or inconsistent with accepted practice.

We handle peer review denials involving:

  • Lack of medical necessity
  • Insufficient objective findings
  • Excessive treatment frequency
  • Excessive treatment duration
  • Excessive chiropractic care
  • Excessive physical therapy
  • Excessive acupuncture
  • Excessive massage therapy
  • Excessive pain management
  • Excessive diagnostic testing
  • Excessive durable medical equipment
  • Excessive prescription medication
  • Treatment allegedly not causally related to the motor vehicle accident
  • Injury attributed to degeneration or preexisting condition
  • Injury attributed to prior accident
  • Injury attributed to work-related condition
  • Lack of documented improvement
  • Lack of functional gains
  • Gap in treatment
  • Concurrent care by multiple providers
  • Duplicative therapy
  • Services allegedly outside accepted practice standards
  • Surgery allegedly not indicated
  • Injections allegedly not indicated
  • MRIs, CT scans, X-rays, ultrasound, EMG/NCV, or other tests allegedly not indicated
  • DME allegedly not prescribed or not necessary
  • Psychological or psychiatric care allegedly unrelated
  • Dental or TMJ treatment allegedly unrelated
  • Lack of contemporaneous documentation
  • Peer review based on incomplete records
  • Peer review by a reviewer outside the specialty
  • Peer review that does not address the actual CPT codes billed
  • Peer review that relies on boilerplate or conclusory statements
  • Peer review that ignores positive objective findings
  • Peer review that ignores treating physician recommendations

7. Fee Schedule and Coding Denials

New York no-fault reimbursement is governed by fee schedule rules. DFS guidance states that healthcare providers must bill in accordance with no-fault fee schedules, and disputes over fee schedule reductions may be resolved through arbitration or litigation. DFS also notes that charges for qualifying services are subject to fee schedules under Insurance Law Section 5108 and Regulation 83.

We handle fee schedule and coding disputes involving:

  • Fee schedule reductions
  • Wrong conversion factor
  • Wrong geographic region
  • Wrong specialty schedule
  • Wrong CPT code interpretation
  • Wrong HCPCS code interpretation
  • Wrong revenue code interpretation
  • Wrong modifier application
  • Missing modifier allegations
  • Multiple procedure reductions
  • Physical medicine ground rule disputes
  • Chiropractic fee schedule disputes
  • Acupuncture fee schedule disputes
  • Physical therapy fee schedule disputes
  • Occupational therapy fee schedule disputes
  • Nurse practitioner and physician assistant fee schedule disputes
  • Licensed social worker fee schedule disputes
  • Durable medical equipment pricing disputes
  • Prescription drug pricing disputes
  • Pharmacy reimbursement disputes
  • Ambulance fee schedule disputes
  • Surgical billing disputes
  • Anesthesia billing disputes
  • Radiology billing disputes
  • MRI, CT, X-ray, ultrasound, and diagnostic test reductions
  • EMG/NCV billing disputes
  • Bundling and unbundling denials
  • Global surgery package disputes
  • Bilateral procedure reductions
  • Facility fee disputes
  • Hospital billing disputes
  • Article 28 facility billing disputes
  • Out-of-state provider fee schedule disputes
  • Prevailing fee disputes
  • Charges allegedly above permissible rates
  • Denials based on incorrect units
  • Denials based on wrong place of service
  • Denials based on documentation not matching billed code
  • Payment made at a lower rate without proper explanation

8. Assignment of Benefits and Standing Denials

Many no-fault collection cases turn on the Assignment of Benefits. If the carrier claims the assignment is invalid, incomplete, revoked, or missing, it may argue that the provider lacks standing to pursue payment.

We handle AOB and standing denials involving:

  • Missing Assignment of Benefits
  • Defective Assignment of Benefits
  • Assignment not signed by patient
  • Assignment signed by wrong person
  • Assignment signed after treatment
  • Assignment missing provider name
  • Assignment missing patient name
  • Assignment not matching the billing entity
  • Assignment allegedly revoked
  • Assignment allegedly limited
  • Assignment allegedly altered
  • Assignment allegedly not authenticated
  • Carrier claim that provider cannot arbitrate
  • Carrier claim that provider is not the proper assignee
  • Carrier claim that bill was submitted by wrong corporate entity
  • Carrier claim that treatment was rendered by an unlicensed or different provider
  • Carrier claim that the provider is not eligible for direct payment
  • Carrier claim that the patient retained the right to sue
  • Carrier claim that the provider’s assignment does not cover the dates of service

9. Documentation and Billing Defect Denials

Insurance companies often deny claims based on alleged paperwork problems. Some are curable. Some are legally insufficient. Some are pretextual. We help providers identify which problems matter and which denials can be challenged.

We handle documentation denials involving:

  • Missing NF-3
  • Missing UB-04
  • Missing HCFA/CMS-1500
  • Missing itemized bill
  • Missing medical report
  • Missing SOAP notes
  • Missing treatment plan
  • Missing prescription
  • Missing referral
  • Missing diagnostic report
  • Missing operative report
  • Missing invoice
  • Missing proof of delivery for DME
  • Missing proof of mailing
  • Missing license information
  • Missing tax ID
  • Missing NPI
  • Missing CPT codes
  • Missing ICD-10 codes
  • Missing modifiers
  • Missing dates of service
  • Missing patient signature
  • Missing provider signature
  • Missing supervising physician information
  • Missing treating provider credentials
  • Illegible records
  • Inconsistent dates
  • Inconsistent patient information
  • Incorrect claim number
  • Incorrect policy number
  • Incorrect accident date
  • Duplicate billing allegations
  • Billing for services allegedly not rendered
  • Billing for supplies allegedly not delivered
  • Billing under the wrong provider entity
  • Billing outside the provider’s lawful scope of practice

10. Policy Exhaustion, Limits, Deductibles, and Offset Denials

Carriers often deny claims by arguing that benefits have been exhausted or reduced by another source. New York DFS describes basic no-fault coverage as up to $50,000 per person, and the mandatory endorsement provides for reductions by amounts recoverable under workers’ compensation, Social Security disability, and other statutory sources.

We handle disputes involving:

  • Basic economic loss exhausted
  • Policy limits exhausted
  • Benefits exhausted before provider’s bill was received
  • Benefits exhausted after provider’s bill was received
  • Dispute over order of payment
  • Dispute over priority of bills
  • Dispute over partial exhaustion
  • Deductible applied incorrectly
  • APIP coverage not applied
  • OBEL coverage not applied
  • Optional Basic Economic Loss election disputes
  • Additional Personal Injury Protection disputes
  • Workers’ compensation offset
  • Social Security disability offset
  • New York State disability benefit offset
  • Duplicate benefit allegations
  • Coordination of benefits issues
  • Health insurance offset issues
  • Carrier claim that another insurer is primary
  • Bus, taxi, rideshare, rental, fleet, commercial vehicle, or household policy priority disputes
  • MVAIC priority issues
  • Intercompany and loss-transfer issues affecting payment

11. Causation, Relatedness, and Accident Disputes

Even when coverage exists, insurers may argue that the claimed treatment was not related to the motor vehicle accident.

We handle relatedness and causation denials involving:

  • Treatment allegedly unrelated to the accident
  • Injury allegedly preexisting
  • Injury allegedly degenerative
  • Injury allegedly caused by a prior accident
  • Injury allegedly caused by a later accident
  • Injury allegedly caused by work or sports activity
  • Low-impact collision defenses
  • Lack of objective evidence of injury
  • Delayed onset of symptoms
  • Gap in treatment
  • Different body part than initial complaint
  • Diagnostic findings allegedly chronic or age-related
  • Surgery allegedly related to degeneration rather than trauma
  • Pain management allegedly unrelated to accident injuries
  • Psychological symptoms allegedly unrelated to the accident
  • Dental, TMJ, or facial injury treatment allegedly unrelated

12. Duplicate, Overlapping, and Coordination Denials

Carriers may also deny or reduce claims based on alleged duplication or overlap among providers.

We handle denials involving:

  • Duplicate billing
  • Same service billed by multiple providers
  • Multiple providers billing same CPT code
  • Concurrent physical therapy and chiropractic care
  • Concurrent acupuncture and physical therapy
  • Concurrent pain management and rehabilitation services
  • Duplicate diagnostic testing
  • Multiple MRIs or repeat imaging
  • Multiple DME devices allegedly duplicative
  • Same-day billing disputes
  • Same provider billing under multiple entities
  • Global period and bundled care disputes
  • Coordination with workers’ compensation or health insurance

No-Coverage Defenses in New York No-Fault Claims

A “no coverage” defense is different from an ordinary claim defense. Ordinary claim defenses may be subject to strict no-fault timing and preclusion rules. But New York courts have recognized that a late denial generally cannot create coverage where the policy never covered the claim in the first place. In Fair Price Medical Supply Corp. v. Travelers, the court discussed the distinction between defenses that challenge coverage in the first instance and ordinary claim defenses.

Because no-coverage defenses can have serious consequences for providers, they must be reviewed carefully. We analyze the facts, the policy, the denial, the mailing proof, the claim history, and the insurer’s evidence.

No-Coverage and Eligibility Defenses We Handle

Carriers may assert no coverage based on the categories below.

Policy and Vehicle Coverage Issues

  • No policy in effect on the accident date
  • Policy cancelled before the accident
  • Policy lapsed for nonpayment
  • Policy rescinded or voided
  • Vehicle not insured by the responding carrier
  • Wrong insurer identified
  • Wrong policy number
  • Vehicle not a covered auto
  • Vehicle excluded from the policy
  • Vehicle not required to carry financial security
  • Accident outside the covered policy period
  • Claim belongs to another carrier
  • Claim belongs to MVAIC
  • Claim belongs to a household policy
  • Claim belongs to the occupied vehicle’s insurer
  • Priority of coverage dispute
  • Out-of-state policy issue
  • Rental vehicle coverage issue
  • Fleet or commercial vehicle coverage issue
  • Livery, taxi, or bus coverage issue
  • Rideshare or transportation network company coverage issue
  • Peer-to-peer car sharing coverage issue

Person Not Eligible for No-Fault Benefits

  • Injured person was not an eligible injured person
  • Injured person was not an insured, passenger, pedestrian, or qualifying covered person
  • Injured person was occupying a motorcycle
  • Injured person was riding an ATV
  • Injured person was the owner of an uninsured vehicle
  • Injured person was occupying or struck by their own uninsured vehicle
  • Injured person was excluded under the policy
  • Injured person was covered by another no-fault policy
  • Injured person’s status as New York resident or nonresident is disputed
  • Injured person’s status as pedestrian, passenger, driver, operator, owner, employee, or household relative is disputed
  • Injured person was not in the vehicle alleged
  • Injured person was not involved in the accident alleged

Accident Not Covered by No-Fault

  • Injury did not arise out of the use or operation of a motor vehicle
  • No motor vehicle accident occurred
  • Accident was staged
  • Accident was intentional
  • Incident involved assault rather than vehicle use
  • Injury occurred during loading or unloading dispute
  • Injury occurred during vehicle repair or service business operations
  • Injury did not occur in New York or within the covered territorial scope
  • Hit-and-run or uninsured accident requiring MVAIC analysis
  • No causal relationship between accident and claimed injury
  • Claimed treatment relates to a prior accident
  • Claimed treatment relates to a work injury
  • Claimed treatment relates to degeneration or a non-accident condition

Statutory and Policy Exclusions

The mandatory New York PIP endorsement and DFS guidance identify several circumstances where coverage may not apply, including intentional self-injury, occupying a motorcycle, intoxicated or drug-impaired operation that contributes to the accident subject to emergency-service rules, felony conduct, avoiding arrest, racing or speed testing, occupying or operating a known stolen vehicle, and repairing or servicing a vehicle in the course of a repair business where the injury occurs on business premises.

We handle defenses involving:

  • Intentional self-injury
  • Driving while intoxicated
  • Driving while impaired by drugs
  • Emergency health services exception for intoxication-related denials
  • Injury while committing a felony
  • Injury while fleeing or avoiding lawful apprehension
  • Injury during a race or speed test
  • Injury while operating or occupying a known stolen vehicle
  • Injury while repairing, servicing, or maintaining a vehicle in a repair business on business premises
  • Motorcycle occupant exclusion
  • ATV occupant exclusion
  • Uninsured-owner exclusion
  • Transportation network company coverage issues
  • Peer-to-peer car sharing coverage issues

Fraud, Staged Accident, and SIU Defenses

We also handle carrier denials based on:

  • Staged accident allegations
  • Fraudulent accident allegations
  • Material misrepresentation allegations
  • Misrepresentation in policy procurement
  • Misrepresentation in claim presentation
  • Fraudulent billing allegations
  • Services allegedly not rendered
  • DME allegedly not delivered
  • Patient allegedly not injured
  • Treatment allegedly unrelated
  • Collision facts inconsistent with injury
  • Low-impact accident allegations
  • Prior claim history allegations
  • SIU investigation pending
  • Declaratory judgment action filed by carrier
  • Global denial based on coverage investigation
  • Alleged false statements by insured or claimant
  • Alleged false address or garaging information
  • Alleged false employment or wage information
  • Alleged provider participation in claim scheme

Provider Eligibility, Licensing, and Corporate Practice Defenses

Carriers may attempt to deny provider claims based on licensing, ownership, corporate structure, or alleged professional misconduct. New York’s Court of Appeals held in Mallela that insurers may withhold payment from fraudulently incorporated medical corporations seeking no-fault reimbursement. In Government Employees Ins. Co. v. Mayzenberg, decided November 24, 2025, the Court of Appeals held that an insurer may not deny no-fault reimbursement based solely on alleged professional misconduct, such as paying referral fees, unless the misconduct amounts to a foundational licensing failure, such as ceding control of the professional practice to unlicensed individuals.

We handle defenses involving:

  • Fraudulent incorporation allegations
  • Mallela defenses
  • Carothers-style control allegations
  • Nonphysician ownership or control allegations
  • Nonlicensee ownership or control allegations
  • Unlicensed control of professional corporation
  • Management company control allegations
  • Fee-splitting allegations
  • Kickback or referral fee allegations
  • Provider licensing disputes
  • Corporate practice of medicine allegations
  • Services outside scope of license
  • Entity not eligible for reimbursement
  • Billing entity mismatch
  • Provider not licensed on date of service
  • Facility not authorized to bill for service
  • Article 28 facility issues
  • Professional misconduct allegations
  • Declaratory judgment actions seeking to stop provider arbitrations
  • Carrier lawsuits seeking reimbursement of previously paid claims

Provider Specialties We Represent in No-Fault Collections

We pursue unpaid no-fault claims for a wide range of medical providers, facilities, and healthcare businesses. Claims must be accident-related, medically necessary, properly documented, within the provider’s lawful scope of practice, and billable under applicable no-fault rules.

Medical and Surgical Providers

  • Orthopedic surgeons
  • Spine surgeons
  • Neurosurgeons
  • Pain management physicians
  • Physical medicine and rehabilitation physicians
  • Neurologists
  • Primary care physicians
  • Internal medicine physicians
  • Family medicine physicians
  • Emergency medicine physicians
  • Urgent care providers
  • Anesthesiologists
  • Podiatrists
  • Dentists
  • Oral surgeons
  • Maxillofacial surgeons
  • TMJ specialists
  • ENT providers
  • Ophthalmologists
  • Plastic and reconstructive surgeons
  • Sports medicine physicians
  • Occupational medicine providers
  • Rheumatologists where accident-related
  • Vascular specialists where accident-related
  • Wound care providers where accident-related

Rehabilitation and Conservative Care Providers

  • Chiropractors
  • Physical therapists
  • Occupational therapists
  • Acupuncturists
  • Licensed massage therapists where reimbursable and within scope
  • Rehabilitation facilities
  • Multidisciplinary medical practices
  • Work hardening and functional restoration providers
  • Vestibular therapy providers
  • Balance therapy providers
  • Hand therapy providers
  • Post-surgical rehabilitation providers
  • Concussion rehabilitation providers

Diagnostic and Imaging Providers

  • MRI facilities
  • CT scan facilities
  • X-ray facilities
  • Ultrasound providers
  • Diagnostic imaging centers
  • Radiology groups
  • EMG/NCV providers
  • Neurodiagnostic testing providers
  • Electrodiagnostic testing providers
  • Ambulatory diagnostic centers
  • Independent diagnostic testing facilities
  • Laboratory providers where services are accident-related and billable
  • Sleep study providers where accident-related and supported
  • Bone scan and nuclear medicine providers where supported

Facilities and Institutional Providers

  • Hospitals
  • Article 28 facilities
  • Ambulatory surgery centers
  • Outpatient surgical facilities
  • Emergency departments
  • Hospital-owned physician groups
  • Multi-specialty practices
  • Urgent care centers
  • Federally qualified health centers where applicable
  • Rehabilitation clinics
  • Diagnostic and treatment centers
  • Professional corporations
  • Professional limited liability companies
  • Healthcare business entities with valid provider billing rights

Medical Products, Equipment, and Transportation Providers

  • Durable medical equipment suppliers
  • Orthotics providers
  • Prosthetics providers
  • Medical supply companies
  • Pharmacy and prescription drug providers
  • Compound medication providers where legally billable
  • Ambulette providers
  • Ambulance providers
  • Medical transportation providers
  • Home care and nursing providers where covered
  • Post-surgical supply providers
  • Bracing and support device providers
  • TENS unit providers where supported and billable
  • Cervical traction and lumbar traction device providers where supported

Mental Health and Specialty Care Providers

  • Psychiatrists
  • Psychologists
  • Neuropsychologists
  • Licensed clinical social workers
  • Trauma counselors where covered
  • Cognitive rehabilitation providers
  • Brain injury rehabilitation providers
  • Sleep medicine providers where accident-related
  • Headache and concussion specialists
  • Post-concussion therapy providers
  • PTSD and trauma-related care providers where accident-related

Our No-Fault Collections Process

1. Claim Intake and Receivables Review

Send us the denial, bill, assignment, records, and proof of mailing. We review the file to determine whether the claim is collectible and what evidence is needed. For providers with a large receivables portfolio, we can review batches of unpaid claims and prioritize high-value, high-probability collections.

2. Denial Analysis

We identify the carrier’s stated defense, whether the denial was timely, whether the denial preserved the defense, and whether the file supports arbitration, litigation, settlement, or further verification.

3. Documentation and Evidence Preparation

We organize the claim forms, medical records, coding support, fee schedule calculations, and correspondence necessary to support your claim. We also identify missing documentation before filing so the file is not weakened by avoidable gaps.

4. Carrier Communication and Settlement Strategy

Some claims can be resolved before a hearing. Others require formal arbitration or litigation. We evaluate the best route for each claim based on amount, defense, carrier, documentation, forum, prior rulings, and risk.

5. Arbitration or Litigation

We pursue payment through the appropriate forum, including AAA no-fault arbitration or court litigation. DFS states that denied or late no-fault claims may be addressed by complaint, arbitration, or court action.

6. Award, Judgment, and Post-Award Collection

Winning the award is only part of the process. We track unpaid awards, follow up with carriers, and pursue collection when payment is not timely made. DFS guidance notes that if an arbitration award is unpaid after the required period, the claimant should follow up with the respondent in writing regarding the unpaid award elements.

Documents to Send for a No-Fault Collections Review

For the strongest review, send:

$

NF-10 denial

$

NF-3 or provider bill

$

CMS-1500, HCFA, UB-04, or itemized bill

$

Assignment of Benefits

$

Proof of mailing

$

Payment explanation or EOB

$

Claim number

$

Policy number

$

Date of accident

$

Dates of service

$

Medical records

$

SOAP notes

$

Diagnostic reports

$

Prescriptions and referrals

$

Operative reports

$

Verification requests and responses

$

Peer review reports

$

IME notices and reports

$

EUO notices

$

EOBs and payment ledgers

$

Prior arbitration awards, if any

$

Patient intake documents

$

Police accident report, if available

$

Claim correspondence

$

AR aging report or unpaid receivables export

Why Fast Action Matters

No-fault claims are document-driven. The longer a denied bill sits, the harder it can become to locate proof of mailing, reconstruct claim timelines, find missing records, and respond to carrier defenses. A quick review can help preserve the strongest arguments, identify missing documents, and determine whether the carrier’s denial is collectible.

Frequently Asked Questions

What is a no-fault collections lawyer?

A no-fault collections lawyer helps medical providers recover unpaid bills for treatment rendered to patients injured in motor vehicle accidents. The lawyer reviews denials, prepares evidence, and pursues payment through arbitration, litigation, settlement, or post-award collection.

Can a medical provider file no-fault arbitration in New York?

Yes. A medical provider that has a valid Assignment of Benefits may file as the injured person’s assignee. DFS states that provider-assignees must submit a completed Assignment of Benefits form signed by the injured party.

What if the insurance company never issued a denial?

A claim may still be collectible if the carrier failed to pay or deny it in a timely manner. DFS guidance states that no-fault benefits are overdue if not paid within the required period after the insurer receives proof of claim, including requested verification.

What if the carrier says the claim is still pending verification?

We review whether the verification request was timely, specific, properly mailed, and followed up under no-fault rules. A pending verification defense should be checked carefully because repeated or improper verification requests can create disputes over whether the carrier’s time to pay or deny was actually tolled.

What if the denial is based on an EUO no-show?

EUO no-show denials require careful review. We look at whether the EUO request was valid, whether notices were properly mailed, whether the EUO was reasonably convenient, whether a second opportunity was provided, and whether the denial was timely.

What if the denial is based on an IME cutoff?

An IME cutoff does not automatically defeat a provider’s claim. We review the IME notice, attendance history, report, specialty, cutoff date, records reviewed, medical rationale, and whether the denial properly applies to the dates and services billed.

What if the carrier paid less than the billed amount?

Partial payments often involve fee schedule disputes, coding disputes, modifier issues, bundling arguments, regional conversion factors, or ground rule interpretations. Fee schedule reductions can be challenged through arbitration or litigation when the carrier’s calculation is wrong or unsupported.

What if the carrier says benefits are exhausted?

Policy exhaustion must be proven. We review the ledger, order of payment, dates bills were received, whether other payments were properly made, and whether APIP, OBEL, or other coverage applies.

What if the carrier claims no coverage?

No-coverage defenses require detailed legal and factual review. A no-coverage defense may involve no policy, wrong carrier, staged accident, ineligible person, uninsured vehicle, motorcycle exclusion, intoxication, felony conduct, stolen vehicle, or other statutory or policy exclusions. Because no-coverage defenses can be treated differently from ordinary denials, they should be evaluated quickly.

Can a provider bill the patient after a no-fault denial?

It depends on the reason for denial, the assignment language, and the provider’s agreement with the patient. DFS guidance states that when a provider accepted an Assignment of Benefits and payment is denied based on IME or medical necessity, the provider should pursue the remedy in arbitration or court rather than billing the patient directly. Coverage exclusions, policy exhaustion, and lack-of-coverage issues require separate analysis.

Your consultation with The Rozhik Law Firm is completely free. We’ll help you understand what your case may realistically be worth — honestly and without pressure.

Speak with a Brooklyn Personal Injury Lawyer Today

If you or a family member has been injured in Brooklyn, do not wait. Evidence disappears. Witnesses become harder to locate. Deadlines approach. The sooner you have a knowledgeable attorney in your corner, the better positioned you are to recover the maximum compensation available to you.

At The Rozhik Law Firm, your first consultation is always free. We work on a contingency fee basis — meaning you never owe us anything unless we win your case. Our office is located at 2533 Batchelder Street, Suite 2C, Brooklyn, NY 11235, and we are available to take your call around the clock.

Call (917) 567-1963 or fill out the contact form to the right to get started today.

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