ABC Medical Management, Inc. v. GEICO General Insurance
The case addresses whether a plaintiff-assignee medical equipment supplier can recover no-fault first-party benefits when a chiropractor, rather than a physician, issued the prescription. Defendant GEICO General Insurance Company moved for summary judgment, arguing that Education Law § 6551 prohibits chiropractors from prescribing such items. The court denied GEICO's motion, ruling that chiropractors are permitted to prescribe TENS units, thermophore devices, and similar medical supplies, as these do not constitute 'drugs or medicines' under the Education Law. Furthermore, the court found that GEICO failed to properly present its medical necessity defense and that the contested issues should be determined by a trier of fact.