Schwartz, Conroy & Hack, PC is proud to share a significant victory – not just for our firm, but also for accident victims and health care providers throughout New York State. On November 24, 2025, Partner Matthew J. Conroy obtained a decisive ruling from the New York Court of Appeals in Government Employees Insurance Co. v. Mayzenberg. New York’s highest court rejected GEICO’s attempt to deny no-fault reimbursements to a duly licensed medical provider based solely on the insurer’s own allegations of professional misconduct. The decision reaffirmed the core purpose of New York’s no-fault system: to ensure that people injured in motor vehicle accidents can get medical care quickly – and that providers are paid promptly for the care they deliver.
Not just a courtroom win, the ruling protects accident victims and health care providers statewide against a troubling tactic increasingly used by insurers: turning regulatory language into a financial weapon.
What GEICO Tried to Do – and Why It Matters
GEICO asked the federal courts (and ultimately the Court of Appeals) to expand a no-fault regulation – 11 NYCRR 65-3.16(a)(12) – that allows an insurance company to deny reimbursement to health care providers who fail “to meet any applicable New York State or local licensing requirement necessary to perform such service in New York.” GEICO wanted to broaden the regulation so that insurers could refuse payment whenever they unilaterally claim a provider engaged in professional misconduct, such as paying third parties for referrals. GEICO asserted that this type of professional misconduct would render the provider ineligible for reimbursement for no-fault claims on the ground that the provider failed to meet a necessary licensing requirement under the regulation.
GEICO’s position would have let insurers function as judge, jury, and executioner over provider eligibility, without any prior finding by New York’s licensing authorities.
That move was more than aggressive lawyering. If accepted, it would have:
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- shifted disciplinary power away from state regulators (the Board of Regents/Office of Professional Discipline) and into insurers’ hands,
- opened the door to blanket denials based on unproven allegations, and
- encouraged delay-and-deny strategies that choke provider cash flow, reduce treatment capacity, and ultimately harm patients.
As the Court recognized, this type of insurer overreach would undermine the no-fault law’s express goals of swift compensation and reduced litigation.
What the Court Held
In answering the certified question that was before it in the negative, the Court of Appeals adopted the Department of Financial Services’ (DFS) interpretation of the regulation. The Court asserted that an insurer may not deny no-fault benefits just because it alleges a licensed provider committed professional misconduct like paying referral fees – unless the conduct amounts to a foundational licensing failure, such as ceding control of the practice to unlicensed individuals.
The Court emphasized several critical points that protect providers and patients statewide:
- Licensing requirements mean “prerequisites to be licensed,” not every rule of professional conduct. The Court said DFS’s reading was “rational” and consistent with the regulation’s text and the broader Education Law framework.
- Only state licensing authorities can adjudicate professional misconduct. Insurers cannot sidestep that system by declaring, on their own, that misconduct occurred and then cutting off care payments.
- No-fault exists to ensure prompt medical treatment and payment. GEICO’s approach would delay reimbursements and multiply litigation – exactly what no-fault laws were designed to prevent.
This is a direct repudiation of an insurer playbook that tries to stretch fraud-prevention language into a broad cost-avoidance tool.
How This Decision Protects Providers and Injured New Yorkers
When insurers can deny payment based on allegations alone, providers are forced into endless verification fights, arbitrations, and lawsuits just to get paid for medically necessary care. That has real-world consequences:
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- clinics and practices pull back from treating no-fault patients,
- accident victims struggle to find timely care, and
- New York’s no-fault system becomes a battlefield, not a safety net.
The Court of Appeals recognized that GEICO’s theory would incentivize insurers to test new denial grounds across the entire landscape of alleged professional misconduct – creating uncertainty and delay far beyond this case.
By stopping that expansion, the decision preserves:
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- provider stability,
- patient access to treatment, and
- the legislature’s bargain: prompt payment in exchange for reduced litigation.
Our Commitment: Holding Insurers to the Law, Not Their Balance Sheets
Mayzenberg is the latest example of what Schwartz, Conroy & Hack, PC does every day: beat back overreaching insurance companies that try to manipulate the law to serve their own financial objectives at the expense of providers and the public. Insurers are entitled to investigate fraud. They are not entitled to rewrite the rules so they can deny valid claims by accusation, delay, or litigation pressure. The Court of Appeals’ decision draws that line clearly. We’re proud to have been the team that brought this issue before New York’s highest court and secured a win that will protect providers and patients across the state.
About Schwartz, Conroy & Hack, PC
Schwartz, Conroy & Hack, PC is a leader in insurance recovery and complex business litigation. We represent health care providers, policyholders, and businesses facing sophisticated insurer tactics designed to avoid contractual and statutory obligations. Our work protects not only individual clients, but also the integrity of systems New Yorkers rely on – like no-fault coverage after a motor vehicle accident. If your insurance claim has been denied or is being challenged, contact us. We have the expertise and tenacity to make insurance companies keep the promises they made to you and your business.
