Volume 17

Case Search

NU-BEST WHIPLASH INJURY CENTER, INC., a/a/o JAN AVERY, GALE BAUER, LISA COLON, DORIAN DOMINGUE, ROBERT MCANELLY, and CATALINA THOMAS, Appellant, v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Appellee.

17 Fla. L. Weekly Supp. 1164a

Online Reference: FLWSUPP 1712NUBEInsurance — Personal injury protection — Coverage — Medical expenses — CPT coding — Where there was conflicting testimony concerning whether videofluoroscopy machine used by medical provider was synonymous with cineradiography or videoradiography machines covered by CPT code applied by insurer, trial court erred in entering summary judgment finding that insurer applied correct code

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FIDEL S. GOLDSON, D.C., P.A., a Florida Corporation (assignee of White, Tanya), Plaintiff, v. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant.

17 Fla. L. Weekly Supp. 394a

Online Reference: FLWSUPP 1705WHITInsurance — Personal injury protection — Delay in payment — Request for information or documentation — Request in explanation of benefits for specific description of non-specific CPT code did not toll time for payment of benefits where claim form submitted to insurer lists description of code as “cervical pillow”

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CENTURY HEALTH & REHAB, INC., a Florida Corporation (assignee of Jarbath, Guy), Plaintiff, v. STATE FARM FIRE AND CASUALTY COMPANY, Defendant.

17 Fla. L. Weekly Supp. 854b

Online Reference: FLWSUPP 1709 JARBInsurance — Personal injury protection — Coverage — Medical expenses — Claim form — CPT coding — National Corrective Coding Initiative edits apply to PIP claims — Although provider submitted HCFA form which listed office visit code without required -25 modifier to indicate that it was distinct procedure from chiropractic manipulation performed on the same date, medical bill was nonetheless substantially compliant where provider’s accompanying SOAP notes listed the office visit code with a -25 modifier

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UNITED AUTOMOBILE INSURANCE COMPANY, Appellant, v. APPLE MEDICAL CENTER, LLC, a/a/o Dexter Jones, Appellee.

17 Fla. L. Weekly Supp. 1057a

Online Reference: FLWSUPP 1711JONEInsurance — Personal injury protection — Coverage — Medical expenses — CPT coding — Evidence — Error to exclude affidavit of insurer’s non-physician expert regarding correctness of CPT code on claim form where PIP statute does not require that insurer refute medical provider’s CPT code determination with physician’s affidavit — Where excluded affidavit and provider’s deposition present material factual dispute regarding treatment billed as disputed CPT code, summary judgment and final judgment are reversed

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CEGA STRESS & ESTHETIC CENTER, INC, a/a/o CHRISTIAN VELEZ, Plaintiff, vs. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant.

17 Fla. L. Weekly Supp. 830c

Online Reference: FLWSUPP 1709VELEInsurance — Personal injury protection — Coverage — Medical expenses — CPT coding — Where PIP statute requires compliance with Medicare’s National Correct Coding Initiative, which provides that medical provider cannot bill lesser code separately on same date as provider bills bundled code that includes lesser code, insurer is not required to pay charge for lesser code

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ALEXANDRA HEALTHCARE, LLC d/b/a KIRKMAN CHIROPRACTIC a/a/o JUSTIN CORTES, Plaintiff, vs. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant.

17 Fla. L. Weekly Supp. 826a

Online Reference: FLWSUPP 1709ALEXInsurance — Personal injury protection — Coverage — Medical expenses — CPT coding — National Correct Coding Initiative is incorporated in Florida PIP law as part of Medicare pay system — Where medical provider improperly unbundled services when billing, neither insured nor insurer was obligated to pay provider for unbundled amounts — Question certified

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ALEXANDRA HEALTHCARE, LLC d/b/a KIRKMAN CHIROPRACTIC a/a/o JUSTIN CORTES, Plaintiff, vs. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Defendant.

17 Fla. L. Weekly Supp. 1029a

Online Reference: FLWSUPP 1710CORTInsurance — Personal injury protection — Coverage — Medical expenses — CPT coding — National Correct Coding Initiative is incorporated in Florida PIP law as part of Medicare pay system — Where medical provider improperly unbundles services when billing for comprehensive treatment charge and component treatment charge, neither insurer that paid comprehensive treatment charge nor insured was obligated to pay for unbundled amount — Question certified

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