Pavlova v. Allstate Ins. Co.
This case concerns an appeal regarding first-party no-fault benefits sought by Ksenia Pavlova, D.O., as assignee of Cosby Reavis, against Allstate Insurance Company. The Civil Court had denied the plaintiff's motion for summary judgment and partially granted the defendant's cross-motion, dismissing claims for services billed under CPT code 20999, arguing plaintiff was not entitled to payment under the workers' compensation fee schedule. The Appellate Term modified the Civil Court's order, finding that Allstate's denial of claims for CPT code 20999 was without merit because the insurer failed to request additional documentation as required by 11 NYCRR 65-3.5(b) for "By Report" codes. However, the Appellate Term affirmed the denial of the plaintiff's summary judgment motion, noting the plaintiff failed to demonstrate that claims were not timely denied or that denials were conclusory. The matter was remitted to the Civil Court for a determination on the medical necessity of the CPT code 20999 services, a ground not previously addressed.