JIGNYASA DESAI, D.O., LLC, ETC. v. NEW JERSEY MANUFACTURERS INSURANCE COMPANY (L-5247-21, BERGEN COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedOctober 20, 2022
DocketA-0221-21
StatusPublished

This text of JIGNYASA DESAI, D.O., LLC, ETC. v. NEW JERSEY MANUFACTURERS INSURANCE COMPANY (L-5247-21, BERGEN COUNTY AND STATEWIDE) (JIGNYASA DESAI, D.O., LLC, ETC. v. NEW JERSEY MANUFACTURERS INSURANCE COMPANY (L-5247-21, BERGEN COUNTY AND STATEWIDE)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
JIGNYASA DESAI, D.O., LLC, ETC. v. NEW JERSEY MANUFACTURERS INSURANCE COMPANY (L-5247-21, BERGEN COUNTY AND STATEWIDE), (N.J. Ct. App. 2022).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0221-21

JIGNYASA DESAI, D.O., LLC APPROVED FOR PUBLICATION on assignment of H.Y.L., 1 October 20, 2022 Plaintiff-Appellant, APPELLATE DIVISION

v.

NEW JERSEY MANUFACTURERS INSURANCE COMPANY, 2

Defendant-Respondent. ________________________________

Argued October 11, 2022 – Decided October 20, 2022

Before Judges Whipple, Mawla and Smith.

On appeal from the Superior Court of New Jersey, Law Division, Bergen County, Docket No. L-5247-21.

S. Gregory Moscaritolo argued the cause for appellant.

Gregory E. Peterson argued the cause for respondent (Dyer & Peterson, PC, attorneys; Gregory E. Peterson, on the brief).

1 We use initials to protect the patient's privacy, pursuant to Rule 1:38-3(a). 2 Respondent is interchangeably referred to as New Jersey Manufacturer's Insurance Group and New Jersey Manufacturer's Insurance Company by the parties and the documents contained within the appellate record. The opinion of the court was delivered by

MAWLA, J.A.D.

Plaintiff Jignyasa Desai, D.O., LLC appeals from a September 20, 2021

Law Division order denying its request to modify an arbitration award

involving defendant New Jersey Manufacturer's Insurance Company (NJM),

regarding reimbursement for nerve tests performed on plaintiff's patient,

H.Y.L. We reverse and remand for entry of an award in plaintiff's favor,

consistent with this opinion.

The parties' dispute was arbitrated pursuant to the Alternative Procedure

for Dispute Resolution Act (APDRA), N.J.S.A. 2A:23A-1 to -19. A dispute

resolution professional (DRP) found for defendant, and plaintiff appealed to a

three-DRP panel, which affirmed the original award by a majority ruling.

Plaintiff appealed from the panel's decision, and a Law Division judge

affirmed in an oral opinion.

On this appeal, plaintiff urges us to exercise our supervisory function

and reverse, arguing there is a split in authority in the interpretation of the

governing regulation, N.J.A.C. 11:3-29.4(e). The regulation states:

[T]he insurer's limit of liability for any medical expense benefit . . . not set forth in or not covered by the fee schedules shall be a reasonable amount considering the fee schedule amount for similar services . . . . When a [current procedural terminology (CPT)] code for the service performed has been A-0221-21 2 changed since the fee schedule rule was last amended, the provider shall always bill the actual and correct code found in the most recent version of the . . . [CPT book]. The amount . . . the insurer pays for the service shall be in accordance with this subsection. Where the fee schedule does not contain a reference to similar services or equipment as set forth in the preceding sentence, the insurer's limit of liability for any medical expense benefit for any service or equipment not set forth in the fee schedules shall not exceed the usual, customary and reasonable [(UCR)] fee.

[Ibid.]

The American Medical Association (AMA) promulgates CPT codes for

every procedure reimbursable by medical insurance providers. 3 The CPT

codes contain no fee schedules, basic units, relative values, or related listings.

N.J.A.C. 11:3-29.2. Rather, the Commissioner of the New Jersey Department

of Bank and Insurance (DOBI) promulgates the fee schedule. N.J.S.A. 39:6A-

4.6. Therefore, the CPT codes and the fee schedules may sometimes be out of

synch.

Plaintiff started a course of treatment for H.Y.L., which involved

electromyography and nerve conduction velocity (NCV), or nerve conduction

study tests. Plaintiff received approval for the testing under CPT code 95913,

3 See CPT Codes, Then and Now, American Medical Association (Aug. 4, 2015), https://www.ama-assn.org/practice-management/cpt/cpt-codes-then- and-now.

A-0221-21 3 which is defined as "[thirteen] or more nerve studies." It then conducted

twenty separate NCV tests, which contained three different types of tests

coded in the New Jersey fee schedule at the time, including: Eight motor

nerve studies coded under 95903; ten sensory tests under 95904; and two "H"

tests under 95934. These three codes are no longer recognized by the CPT

book and have been consolidated under one current code, 95913. 4 "These

changes were made in an effort to address the overlap in the pre-test and post-

test work involved in the procedures." Ibid. As a result, CPT 95913 does not

differentiate the type of test, rather, the code represents the administration of

"[thirteen] or more" tests.

Under the old codes, the prices per unit for the tests were as follows:

95903, $176.35; 95904, $135.64; and 95934, $155.93. Thus, the total billed

under the old codes for H.Y.L. would be $3,079.06 ((176.35 x 8) + (135.64 x

10) + (155.93 x 2)). Plaintiff billed $9,585 using CPT 95913. Defendant

reimbursed $2,292.55, representing $176.35, the per unit price of the most

expensive old test code, CPT 95903, multiplied by thirteen.

Pursuant to N.J.A.C. 11:3-29.4(e), when a code is updated it is cross-

referenced to the old code that it replaced. This process is commonly referred

4 Nerve Conduction Studies (Codes 95907-95913) (March 2013), AMA CPT Assistant, https://www.findacode.com/newsletters/ama-cpt-assistant/index. html.

A-0221-21 4 to as "cross-walking."5 Plaintiff argued this method required defendant to

"cross-walk" the tests performed back to the old codes, 95903, -04, and -34,

which correspond to the current code, 95913, resulting in an additional

$786.51 for the additional seven tests performed.

During arbitration, each party provided expert testimony to support its

view of the billing dispute. The DRP found NJM "sufficiently reimbursed"

plaintiff. Moreover, based on the evidence defendant presented, the DRP

concluded "the relative value units . . . for the NCS portion of the testing has

been modified by the AMA" to lower the value of the testing under the form er

codes. A majority of the DRP panel affirmed holding "[t]he CPT code

language for CPT 95913 caps reimbursement at [thirteen] studies. There is no

mistake of law or misapplication of the regulation."

The Law Division judge noted "if this is not decided consistently[,] it's

going to cause more problems going forward . . . ." However, he concluded

"this is a UCR case. It is not a crosswalk situation. And I have no reason to

disturb the factual findings below[,] which led to [the DRP] deciding the case

the way [they] did." The judge further found "[t]his is not a coding dispute

between the parties[]" because it deals with "reimbursement of NCV testing

5 Crosswalking, MB&CC, https://www.medicalbillingandcoding.org/crosswal king/.

A-0221-21 5 . . . under an agreed code." He concluded the correct method was not to

crosswalk "because the way it's coded now there's no differentiation at all."

The DRP's decision "was supported substantially by the factual information

given to the DRP below and . . . the reason for the CPT code change was to

prevent or someway restrict what was considered at that time as . . . overbilling

by medical providers."

I.

When parties "knowingly agree[] to resolve their disputes under the

APDRA," they agree to a limited right of appeal. Mt. Hope Dev. Assocs. v.

Mt. Hope Waterpower Project, L.P., 154 N.J.

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JIGNYASA DESAI, D.O., LLC, ETC. v. NEW JERSEY MANUFACTURERS INSURANCE COMPANY (L-5247-21, BERGEN COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/jignyasa-desai-do-llc-etc-v-new-jersey-manufacturers-insurance-njsuperctappdiv-2022.