New York Court of Appeals
Government Employees Ins. Co. v. Mayzenberg
November 24, 20252025 NY Slip Op 06527
Summary
The Court answered the certified question in the negative, holding that an insurer may not deny no-fault reimbursement solely because it determines that a properly licensed provider engaged in professional misconduct by paying for patient referrals. The regulation reaches foundational licensing requirements and circumstances in which control of a professional corporation is ceded to unlicensed persons, but not professional misconduct that has not resulted in loss of licensure or equivalent control. The Court deferred to the Department of Financial Services' rational interpretation because it aligned with the regulation's text, the licensing framework, and the no-fault system's prompt-payment purposes.