New York’s no-fault system generates more chiropractic billing disputes than almost any other state in the country. The rules are layered, the deadlines are unforgiving, and insurers know exactly how to exploit a procedural misstep. For chiropractors treating auto accident patients, ignorance of these guidelines isn’t just inconvenient — it’s expensive.

This guide cuts through the regulatory complexity. It covers every operational reality a practicing chiropractor in New York must command: the governing statutes, the correct fee schedule, CPT code restrictions, mandatory filing windows, and the legal remedies available when an insurer refuses to pay.

What Is New York No-Fault Insurance, and Does It Cover Chiropractic Care?

New York no-fault insurance covers medically necessary treatment for injuries sustained in a motor vehicle accident, regardless of who caused the crash. Under Article 51 of the New York Insurance Law, all auto policies issued in New York must include a minimum of $50,000 in Personal Injury Protection (PIP) benefits. Chiropractic care is explicitly covered when it is medically necessary and causally related to the accident.

That $50,000 PIP benefit sounds generous. In practice, it disappears quickly when carriers aggressively apply IME cutoffs, concurrent-care denials, and fee schedule reductions. Chiropractic treatment is one of the most commonly reimbursed services under no-fault — and one of the most aggressively challenged. A chiropractor who understands the framework before the first patient visit avoids the most costly mistakes downstream.

New York’s no-fault system is a pure first-party model. The patient’s own insurer pays for treatment, not the at-fault driver’s carrier. This matters operationally: all claims go to the patient’s auto insurer, and the chiropractor bills as an assignee of benefits once the patient signs over their rights.

What Regulations Govern No-Fault Billing for Chiropractors in New York?

Two regulatory frameworks control no-fault chiropractic billing in New York. Regulation 68 (11 NYCRR Part 65), administered by the New York Department of Financial Services (DFS), governs the claims process — submission deadlines, insurer response obligations, verification requests, and arbitration procedures. Regulation 83 (11 NYCRR 68), also a DFS instrument, governs the fee schedule and the maximum permissible reimbursement rates for each service category.

Critically, the 35th Amendment to Regulation 83 took effect October 1, 2020, adopting the NYS Workers’ Compensation Board’s Chiropractic Fee Schedule for no-fault claims. This was a watershed moment. It replaced the outdated flat-rate structure and introduced relative value units (RVUs) multiplied by regional conversion factors to calculate reimbursement. The New York State Chiropractic Association (NYSCA), which had opposed the delayed adoption, worked with the New York Chiropractic College (NYCC) to educate providers through webinars ahead of the transition.

One amendment’s impact was immediate and significant: chiropractors lost the ability to bill outside their designated fee schedule section. Services billed under physician or physical therapy rates — a practice some medical professional corporations had relied on — became prohibited. Any chiropractor working under a medical PC must still bill at chiropractic fee schedule rates regardless of the supervising physician’s credentials. The New York DFS confirmed this in OGC Opinion No. 02-04-26, and that position has not changed.

What CPT Codes Do New York Chiropractors Use for No-Fault Billing?

For no-fault billing in New York, chiropractors use the following codes for spinal manipulation, categorized by the number of spinal regions treated:

• 98940 – Spinal manipulation, 1–2 regions
• 98941 – Spinal manipulation, 3–4 regions
• 98942 – Spinal manipulation, 5 regions

Initial evaluations use the following codes and must include a comprehensive history, clinical testing, data interpretation, and a defined plan of care:

• 99202 – New patient office visit, low complexity
• 99203 – New patient office visit, moderate complexity
• 99204 – New patient office visit, moderate-high complexity

Follow-up visits allow billing up to 12 relative value units per encounter.

The practical implication of the RVU system is that a well-documented follow-up visit is worth far more than a simple adjustment alone. A chiropractor who provides and documents therapeutic exercise, neuromuscular re-education, or other medically necessary adjunct services — each carrying its own CPT code and RVU — can legitimately bill for those services and recover meaningful reimbursement. The key word is “documented.” Vague notes do not survive insurer scrutiny or AAA arbitration.

As of October 1, 2020, four service categories were eliminated from the chiropractic reimbursement menu entirely:

• Range of motion testing
• Muscle testing
• Unlisted neurological testing
• Physical performance testing

Manipulation Under Anesthesia (MUA), previously billed by some chiropractors, is also no longer reimbursed under no-fault. Electrodiagnostic testing codes that remain in the chiropractic section are still billable, but at a reduced rate. Understanding what falls outside the fee schedule section is not optional — billing prohibited codes triggers denials and can raise fraud flags.

What Are the Filing Deadlines Every Chiropractor Must Know?

Under Regulation 68, a chiropractor billing no-fault must submit all claims within 45 days of the date of service. The insurer then has 30 calendar days after receiving the bill to pay or deny. If the insurer needs additional verification, it must request it within 15 business days of receiving the claim. Missing either window has consequences — for the provider and the carrier alike.

What Happens If a Chiropractor Misses the 45-Day Billing Deadline?

A chiropractor who submits an NF-3 claim form after the 45-day window may face outright denial of that bill. Under Regulation 68, late submission is a legitimate grounds for denial unless the provider demonstrates a reasonable justification for the delay. Courts and AAA arbitrators scrutinize late-filing defenses carefully, and “administrative oversight” rarely qualifies. Timely submission is the single most preventable source of revenue loss in a chiropractic no-fault practice.

The NF-3 form — officially titled Verification of Treatment by Attending Physician or Other Provider of Health Service — is the standard billing vehicle. Bills submitted on a non-prescribed form are permissible only if they contain substantially the same information as the NF-3. Once submitted, the chiropractor should track receipt and maintain proof of mailing. If the insurer fails to pay or deny within its own 30-day window, interest accrues at 2% simple interest per month on the overdue amount, running from day 30 after the bill should have been received. That penalty is recoverable — but only if the chiropractor can prove timely submission.

How Do Insurance Carriers Deny Chiropractic No-Fault Claims in New York?

New York no-fault insurers deny chiropractic claims on three primary grounds: lack of medical necessity (typically supported by an Independent Medical Examination), the concurrent-care rule under Fee Schedule Ground Rule 6, and procedural defects such as the 45-day late-filing rule or policy coverage exclusions. Each denial must arrive via a Form NF-10 within 30 calendar days of verification, or it is legally defective and potentially unenforceable.

The concurrent-care denial is particularly aggressive and underappreciated. Ground Rule 6 states that when more than one provider treats a patient simultaneously for the same condition, only the provider with the most relevant specialty receives reimbursement. Insurers weaponize this ground rule when a patient sees both a chiropractor and a physical therapist. The resulting NF-10 citations can be challenged, and experienced no-fault attorneys have developed specific arbitration arguments against this denial language — but the provider must document the unique clinical basis for each service.

IME-based denials operate on strict timing rules. Once the insurer schedules and conducts a chiropractic IME, a negative finding triggers the right to issue a prospective denial of all future treatment. That denial, however, must be issued within 30 days of the IME date. Even after an IME-based cutoff, chiropractors who continue treating and submitting bills preserve their right to arbitration. Every subsequent NF-10 denial is its own triggering event. Abandoning claim submission after a cutoff forfeits that right entirely.

What Are a Chiropractor’s Rights When a No-Fault Claim Is Denied?

When a New York no-fault carrier issues a denial via NF-10, a chiropractor holding an assignment of benefits has the right to dispute that denial through AAA (American Arbitration Association) no-fault arbitration. The provider files a Form AR1 with a $40 filing fee, which the insurer must reimburse if the provider prevails. For denials challenged within 90 days, Priority Arbitration under 11 NYCRR 65-4.5 is available and can significantly shorten the path to resolution.

The statute of limitations for filing a no-fault arbitration claim is six years from the date of each denial. That window is long, but acting quickly is always better. Arbitrators evaluate three core questions: Was the claim filed on time? Were the services medically necessary? Was the NF-10 denial issued properly and on time? A technically defective NF-10 — one that is vague, untimely, or lacks a legitimate legal basis — can be challenged on procedural grounds alone, entirely separate from the medical necessity question. For authoritative guidance on arbitration procedures, chiropractors should consult the DFS No-Fault Information page directly.

One critical point about assignment of benefits: once a chiropractor accepts an AOB from a patient, they assume all of that patient’s contractual obligations, including compliance with EUO demands. Refusing an Examination Under Oath constitutes a material policy breach and typically results in a full denial of all pending and future claims. If an EUO demand arrives, notify legal counsel immediately.

Conclusion

New York no-fault chiropractic billing operates at the intersection of insurance law, administrative regulation, and clinical documentation. Regulation 68 and Regulation 83 are not bureaucratic formalities — they are the architecture that determines whether a chiropractor gets paid. The 35th Amendment to Regulation 83 reshaped the billing landscape in October 2020, and providers who haven’t internalized those changes are leaving money on the table and inviting denials they could prevent.

Master the deadlines. Document every service with clinical precision. Know exactly which CPT codes fall within your billable section — and which ones don’t. When a denial arrives, treat it as the beginning of a recoverable claim, not the end of one. The legal infrastructure exists to protect provider reimbursement. Use it.

Disclaimer: This guide is for informational purposes only and does not constitute formal legal or financial advice. Regulations change; always consult with a certified healthcare compliance specialist or healthcare attorney regarding specific billing issues.