The New York Appellate Division of the Supreme Court recently ruled in favor of chiropractor Mark Heyligers, affirming an arbitration award that grants him $3,568.50 in no-fault benefits for medical services rendered. This decision, made on July 9, 2026, impacts healthcare providers and insurance companies involved in no-fault claims, emphasizing the importance of timely communication and adherence to arbitration processes.
The case, titled Matter of American Transit Insurance Company v. Mark Heyligers, DC, was filed under docket number Index No. 653955/25 and involved a dispute over no-fault insurance benefits. The ruling clarifies the responsibilities of insurers when denying claims based on independent medical examinations (IMEs) and the timelines for responding to healthcare providers.
In this case, American Transit Insurance Company (the appellant) challenged the decision of the arbitrators who awarded Heyligers (the respondent) the no-fault benefits. The dispute arose after American Transit terminated the benefits for Heyligers' chiropractic services, claiming that a report from an independent medical examiner indicated that further treatment was unnecessary.
The underlying issue began when Heyligers treated a patient covered by American Transit. The insurance company claimed that an IME report dated February 21, 2023, justified the termination of benefits. However, the court found that the termination date was not when the insurance company decided to cut off benefits but rather when Heyligers was notified on May 1, 2023. This distinction is crucial in determining the timeline for the payment of claims.
The case progressed through the legal system after Heyligers sought to have the arbitration award reviewed by a master arbitrator, as required by law. The master arbitrator upheld the initial award, leading American Transit to file a petition to vacate the award. However, the Supreme Court of New York County denied this petition, prompting the appeal to the Appellate Division.
The Appellate Division unanimously affirmed the lower court's decision, stating, "the arbitrators' decisions were neither arbitrary, capricious, without rational basis, nor contrary to settled law." This ruling underscores the importance of following established procedures in arbitration and reinforces the authority of arbitrators to make binding decisions based on the evidence presented.
Judge Renwick, along with Judges Kapnick, Pitt-Burke, Rosado, and Hagler, presided over the case. They found that American Transit did not adequately challenge the arbitrators' findings regarding the effective date of the termination of benefits. The court noted that the insurance company failed to address Heyligers' argument about the May 1, 2023 cut-off date, which was accepted by the initial arbitrator.
Furthermore, the court highlighted that the insurance company did not contest the finding that a letter from the New York State Insurance Department indicated that the IME's effects would not take place until the insurer provided a timely denial based on that examination. This ruling emphasizes the need for insurance companies to adhere to proper notification procedures when denying claims.
The court also addressed American Transit's argument regarding verification requests sent to Heyligers between July 2022 and July 2023. The court found that, aside from one verification request that Heyligers did not answer, the chiropractor had furnished the necessary information to the insurance company. Consequently, American Transit was required to pay or deny the claims within 30 days of receiving the verifications.
The Appellate Division's ruling has significant implications for both healthcare providers and insurance companies. It reinforces the necessity for insurers to act promptly and transparently when handling no-fault claims. The decision also serves as a reminder that arbitrators have the authority to make binding decisions based on the evidence and arguments presented during arbitration.
Moving forward, this ruling may influence how insurance companies handle no-fault claims and the importance of maintaining clear communication with healthcare providers. It may also encourage healthcare providers to be vigilant in documenting their communications with insurers and ensuring that they respond promptly to any verification requests.
As for the possibility of an appeal, the court's decision is generally considered final unless a party seeks further review from the New York Court of Appeals. However, details were not available in the court filing regarding any related cases pending or whether American Transit intends to pursue further legal action.