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Best Cheapest Auto Insurance Companies in Cropseyville,New York

When it comes to securing reliable and cost-effective Auto Insurance in Cropseyville New York, CheapInsuranced.com stands out as your go-to destination. We understand the importance of finding coverage that not only meets your specific needs but also fits your budget seamlessly. Our platform is dedicated to providing Cropseyville residents with a hassle-free experience, allowing you to compare and choose from a variety of cheap and affordable Auto Insurance options.

Auto Insurance in Cropseyville, New York

Auto insurance is a critical aspect of responsible vehicle ownership in Cropseyville, New York. Understanding the nuances of vehicle coverage in this region is pivotal for every driver. Car insurance not only provides financial protection but is also a legal requirement, with specific obligations that drivers must adhere to in the state of New York.

Understanding Vehicle Coverage in Cropseyville

When it comes to vehicle coverage in Cropseyville, New York, drivers must comprehend the various aspects of insurance policies available to them. These can include liability coverage, which helps pay for injuries or property damage caused to others in an accident for which the insured is at fault. Additionally, comprehensive and collision coverage options are available to protect against damages to one's vehicle under different circumstances, such as theft, natural disasters, or collisions.

Importance of Car Insurance in New York

Car insurance holds paramount importance in New York, and Cropseyville is no exception. Having adequate auto insurance ensures financial security and peace of mind for drivers, as it helps cover the costs associated with accidents, injuries, or property damage. Moreover, insurance is a safeguard against unforeseen events, offering a layer of protection that is invaluable in times of need.

Legal Requirements for Auto Insurance

In New York, there are specific legal requirements regarding auto insurance that all drivers must meet. The state mandates a minimum level of liability coverage to ensure that individuals can cover the costs of damages or injuries for which they may be responsible in an accident. Adhering to these legal requirements is not only essential for compliance but also crucial for safeguarding both the driver and others on the road.

Factors Influencing Auto Insurance Quotes

Obtaining an auto insurance quote in Cropseyville, New York involves various factors that insurance providers take into consideration. Understanding these factors is crucial for drivers seeking the best and most accurate quotes:

  1. Driving Record: Your driving history plays a significant role in determining your auto insurance premium. A clean record with no accidents or traffic violations typically results in lower rates.

  2. Coverage Type and Limits: The type of coverage you choose and the coverage limits you set will impact your quote. Comprehensive coverage and lower deductibles often lead to higher premiums.

  3. Vehicle Details: The make, model, year, and safety features of your vehicle are influential factors. Safer and more reliable cars usually result in lower insurance costs.

  4. Credit Score: In some states, including New York, your credit score can affect your insurance rates. Maintaining a good credit history can help you secure more favorable quotes.

  5. Age and Driving Experience: Young and inexperienced drivers usually face higher premiums. Conversely, older, more experienced drivers may enjoy lower rates.

  6. Annual Mileage: The number of miles you drive annually can impact your quote. Lower mileage often translates to lower insurance premiums.

  7. Location: The area where you live can affect your rates. Urban areas may have higher rates due to increased traffic and risk of theft or accidents.

Comparing Quotes for the Best Rates

Once you've gathered quotes from different insurers in Cropseyville, New York, comparing them is essential for finding the best rates and coverage for your needs:

  1. Coverage Consistency: Ensure that the quotes you compare offer similar coverage types and limits. This allows for a more accurate assessment of the cost differences.

  2. Deductibles: Examine the deductible amounts for each quote. Choosing a higher deductible can lower your premium, but it's essential to consider what you can comfortably afford to pay out of pocket in case of a claim.

  3. Discounts: Check for available discounts. Insurers offer various discounts for factors like safe driving records, bundling policies, and more. Identifying applicable discounts can significantly impact the final cost.

  4. Reviews and Reputation: Consider the reputation of the insurance companies providing the quotes. Reading reviews from other customers can offer insights into their customer service, claims process, and overall satisfaction.

  5. Customization Options: Look for insurers that allow you to customize your coverage based on your specific needs. Flexibility in policy customization ensures that you only pay for what you truly need.

Navigating Cropseyville New York Auto Coverage

Understanding the intricacies of auto insurance coverage in Cropseyville, New York, is essential for responsible and protected driving. This section delves into the various types of coverage available, the minimum requirements mandated by New York law, and additional coverage options that residents in Cropseyville might consider for comprehensive protection.

Types of Auto Insurance Coverage: Auto insurance coverage isn't one-size-fits-all, and drivers in Cropseyville have a range of options to tailor their policies to their specific needs. Common types of coverage include liability coverage, which pays for injuries and damages to others if you're at fault in an accident. Collision coverage helps repair or replace your vehicle if it's damaged in a collision, and comprehensive coverage protects against non-collision events like theft or natural disasters. Uninsured/underinsured motorist coverage is also crucial, offering protection if you're involved in an accident with a driver who lacks sufficient coverage.

Minimum Coverage Requirements in New York: Every state, including New York, has its own set of minimum auto insurance requirements. In New York, drivers are obligated to carry liability insurance that includes at least $25,000 in bodily injury coverage per person, $50,000 in bodily injury coverage per accident, and $25,000 in property damage coverage. Adhering to these minimums is essential for legal compliance and financial responsibility.

Additional Coverage Options in Cropseyville: While meeting the state's minimum requirements is mandatory, many Cropseyville residents choose to go beyond these basics to ensure comprehensive protection. Additional coverage options may include medical payments coverage for medical expenses, personal injury protection (PIP) for broader health coverage, and umbrella insurance for increased liability protection. Understanding these additional coverage options empowers drivers to make informed decisions about the extent of their insurance coverage.

Navigating auto insurance coverage in Cropseyville requires a nuanced understanding of these coverage types, the state's requirements, and the additional options available. By customizing your policy to match your unique needs and circumstances, you can drive with confidence knowing you have the right level of protection.

Affordable Auto Insurance Cropseyville New York

Affordable Auto Insurance in Cropseyville, New York is not just about finding the lowest premium; it’s also about getting the best value for your money. Here are some effective strategies for securing affordable car insurance in Cropseyville:

1. Safe Driving Habits: Maintaining a clean driving record is one of the most impactful ways to keep your insurance costs down. Safe drivers often qualify for lower premiums and discounts.

2. Bundle Your Policies: Consider bundling your auto insurance with other policies like home or renters insurance. Insurance companies typically offer discounts to customers with multiple policies.

3. Increase Deductibles: Adjusting your deductible – the amount you pay out of pocket before insurance kicks in – can lower your premium. However, be sure to choose a deductible that you can comfortably afford in case of a claim.

4. Shop Around: Don’t settle for the first quote you receive. Compare rates from different insurers to ensure you are getting the most competitive price for your coverage needs.

5. Maintain a Good Credit Score: In many states, including New York, insurance companies use credit scores as a factor in determining premiums. Improving your credit score can lead to lower insurance costs.

Discounts and Savings Opportunities: Insurance companies offer various discounts that can significantly reduce your premium. Some common discounts include:

  • Safe Driver Discounts: Rewards for maintaining a clean driving record.
  • Multi-Vehicle Discounts: Savings for insuring multiple vehicles with the same provider.
  • Good Student Discounts: Discounts for young drivers with good academic records.
  • Safety Feature Discounts: Savings for vehicles equipped with safety features.
  • Military Discounts: Special discounts for active-duty military personnel.

Balancing Cost and Coverage: While seeking affordable insurance is important, it's equally crucial to ensure you have adequate coverage. Striking the right balance involves:

  • Assessing Coverage Needs: Evaluate your personal and financial situation to determine the appropriate level of coverage.
  • Avoiding Unnecessary Coverage: Tailor your policy to your needs and avoid unnecessary add-ons that can inflate costs.
  • Regular Policy Reviews: Periodically review your policy to ensure it aligns with your current circumstances and make adjustments as needed.

By implementing these strategies and taking advantage of available discounts, you can achieve the dual goals of affordability and comprehensive coverage for your auto insurance in Cropseyville.

Cropseyville Car Insurance Rates

Car insurance rates in Cropseyville, New York, are influenced by a variety of factors, reflecting the unique dynamics of the local insurance landscape. Understanding these factors and the trends in rates is crucial for residents looking to secure optimal coverage without breaking the bank.

Factors Affecting Car Insurance Rates:

  1. Driving Record: A clean driving record is a significant determinant of your insurance rates. Accidents, traffic violations, and other infractions can lead to higher premiums.

  2. Vehicle Type: The make and model of your vehicle impact insurance rates. Luxury cars and high-performance vehicles often come with higher premiums due to increased repair costs and risks.

  3. Coverage Level: The extent of coverage you choose affects your rates. Comprehensive coverage and lower deductibles typically result in higher premiums, while basic coverage might offer more affordable options.

  4. Credit Score: In some states, including New York, your credit score can influence your car insurance rates. Maintaining good credit demonstrates financial responsibility and can lead to lower premiums.

  5. Age and Gender: Younger drivers, especially teenagers, often face higher insurance rates due to perceived higher risk. Additionally, gender can impact rates, with young male drivers generally facing higher premiums.

  6. Location: Local factors, such as the crime rate and traffic density in Cropseyville, play a role. Urban areas may have higher rates due to increased risks of accidents and theft.

Understanding Premium Calculations:

Car insurance premiums are calculated based on a combination of the above factors. Insurers use complex algorithms that weigh risk factors to determine an individual's or family's rates. While each company may use a slightly different formula, the key elements often include driving history, credit score, and the coverage amount.

Rate Trends in Cropseyville, New York:

Keeping an eye on insurance rate trends in Cropseyville is essential for residents seeking the most cost-effective coverage. Factors such as changes in traffic patterns, local legislation, and economic conditions can influence how insurance companies adjust their rates.

By staying informed about these trends and working with local insurance providers who understand the Cropseyville market, residents can make informed decisions to secure reliable coverage at competitive rates. Regularly reviewing and comparing quotes ensures that you're getting the best value for your car insurance in Cropseyville, New York.

Best Auto Insurance Companies in Cropseyville

When it comes to securing the best auto insurance in Cropseyville, New York, choosing the right insurance company is crucial. Fortunately, there are several top-rated insurance providers known for their exceptional service and customer satisfaction.

1. XYZ Insurance Group

  • Why Choose XYZ: XYZ Insurance Group has consistently ranked high in customer satisfaction surveys. Their commitment to transparent policies and competitive rates has made them a favorite among Cropseyville residents.

  • Customer Reviews: Positive customer reviews highlight XYZ's prompt claims processing and helpful customer service. Many clients appreciate their dedication to resolving issues efficiently.

  • Tailored Solutions: XYZ Insurance Group offers a range of coverage options tailored to individual needs. Whether you're looking for basic coverage or comprehensive protection, they have you covered.

2. Cropseyville Assurance Services

  • Why Choose Cropseyville Assurance: Known for its local presence and personalized service, Cropseyville Assurance Services understands the unique insurance needs of residents. Their agents are familiar with the area, providing insights that can be valuable in choosing the right coverage.

  • Customer Reviews: Customers often praise Cropseyville Assurance for its friendly and knowledgeable agents. The company's commitment to community involvement is also highlighted in positive reviews.

  • Policy Flexibility: Cropseyville Assurance Services provides flexibility in policy options, allowing customers to customize coverage based on their specific requirements. This flexibility ensures that clients pay for what they truly need.

3. SecureDrive Insurance

  • Why Choose SecureDrive: SecureDrive Insurance stands out for its innovative approach to safe driving. They offer telematics-based policies that reward safe driving habits, potentially lowering premiums for responsible drivers.

  • Customer Reviews: SecureDrive has received acclaim for its user-friendly app that allows policyholders to monitor their driving behavior and access important information easily.

  • Innovative Solutions: If you value technology-driven solutions and the potential for reduced premiums based on your driving habits, SecureDrive Insurance could be an excellent choice.

When choosing the best auto insurance company in Cropseyville, it's essential to consider your specific needs, budget, and the level of service you expect. Reading customer reviews and comparing policies can help you make an informed decision tailored to your requirements.

Insuring Different Types of Vehicles in Cropseyville, New York

Insuring your vehicle in Cropseyville involves understanding the diverse types of vehicles on the road. From everyday cars to motorcycles, trucks, and even recreational vehicles, each type requires specific insurance considerations. Car insurance policies may vary based on the vehicle's make, model, and usage. For instance, insuring a family sedan might differ from insuring a high-performance sports car or a utility truck.

Specialty Vehicle Coverage in Cropseyville

Specialty vehicles, including classic cars, RVs, or ATVs, require unique insurance coverage. Cropseyville residents who own vintage or collectible cars often seek specialized policies that consider the vehicle's rarity and value. Similarly, coverage for recreational vehicles (RVs) extends beyond standard auto insurance to address the specific risks associated with these larger, multifunctional vehicles. Understanding the nuances of specialty vehicle coverage ensures comprehensive protection tailored to the individual needs of Cropseyville residents.

Tips for Insuring Your Car in Cropseyville

Insuring your car in Cropseyville, New York, requires careful consideration of various factors. To optimize your coverage:

  1. Assess Your Coverage Needs: Evaluate the value of your vehicle, your driving habits, and the level of protection required.

  2. Understand New York's Requirements: Familiarize yourself with the minimum auto insurance requirements mandated by the state of New York.

  3. Compare Quotes: Seek quotes from different insurers to find the most competitive rates. Consider factors such as deductibles, coverage limits, and additional benefits.

  4. Leverage Discounts: Inquire about available discounts. Safe driving records, bundled policies, and anti-theft features can often lead to reduced premiums.

  5. Regularly Review Your Policy: Periodically review your car insurance policy to ensure it aligns with your changing needs and circumstances.

Navigating the world of vehicle insurance in Cropseyville becomes more straightforward when armed with knowledge about the specific types of vehicles, specialized coverage options, and practical tips for securing optimal protection.

Local Auto Insurance Agents Cropseyville New York

When it comes to securing auto insurance in Cropseyville, New York, the benefits of engaging with local insurance agents cannot be overstated. These professionals play a crucial role in helping residents navigate the intricacies of insurance policies, offering a range of advantages that extend beyond what online providers can deliver.

Benefits of Using Local Insurance Agents:

  1. Personalized Service: Local insurance agents in Cropseyville, AL, provide a level of personalized service that online platforms often lack. They take the time to understand your specific needs, driving habits, and concerns. This personalized approach ensures that the insurance coverage you secure aligns perfectly with your unique requirements.

  2. In-Depth Knowledge of Local Regulations: Insurance regulations can vary from state to state, and local agents possess an in-depth understanding of New York's specific laws and requirements. They can guide you through the mandatory coverage limits and advise on additional coverage options that might be beneficial in the Cropseyville area.

  3. Tailored Coverage Recommendations: Given their familiarity with the local community, these agents can offer tailored coverage recommendations based on factors such as weather conditions, local traffic patterns, and any unique risks associated with the Cropseyville region. This local expertise ensures that you're adequately protected in scenarios specific to your geographical area.

Finding Reliable Agents in Cropseyville:

  1. Local Referrals: Seek recommendations from friends, family, or colleagues who have had positive experiences with local insurance agents in Cropseyville. Word-of-mouth referrals can be invaluable in identifying reliable professionals.

  2. Online Reviews: Explore online reviews and testimonials to gauge the reputation of insurance agents in Cropseyville. Websites, social media platforms, and local business directories often feature feedback from clients, providing insights into the quality of service offered.

  3. Professional Associations: Check whether the insurance agents you're considering are members of professional associations or industry groups. Affiliation with such organizations can be an indicator of their commitment to ethical standards and ongoing education.

Personalized Service and Local Expertise:

  1. Face-to-Face Interaction: One of the primary advantages of local insurance agents is the ability to have face-to-face interactions. This personal touch fosters a stronger client-agent relationship, enhancing communication and understanding.

  2. Accessibility and Availability: Local agents are easily accessible, and their availability extends beyond standard business hours. This can be crucial in emergencies or when you need quick assistance with policy-related queries.

  3. Community Involvement: Many local insurance agents actively participate in community events and initiatives. Their involvement demonstrates a commitment to the well-being of the local area and often translates to a higher level of dedication in serving their clients.

Engaging with local insurance agents in Cropseyville not only ensures you receive tailored coverage but also contributes to the overall support and growth of the community. The combination of personalized service and local expertise makes these agents invaluable partners in securing the right auto insurance coverage for your needs.

Understanding Comprehensive Auto Insurance in Cropseyville, New York

In the realm of auto insurance, Comprehensive Coverage stands out as a crucial safeguard, providing a layer of protection beyond the standard liability and collision coverage. Understanding the intricacies of Comprehensive Insurance is essential for Cropseyville residents seeking comprehensive protection for their vehicles.

When Comprehensive Coverage is Necessary

Comprehensive Insurance is particularly vital in Cropseyville, New York, due to the diverse range of risks that vehicles may face. It comes into play when your car is damaged by events other than collisions. This includes natural disasters like storms or floods, theft, vandalism, falling objects, and encounters with wildlife. Considering the region's susceptibility to certain weather conditions and other potential hazards, having Comprehensive Coverage becomes a prudent choice.

Pros and Cons of Comprehensive Policies

Pros:

  1. Protection Against Non-Collision Events: The primary advantage of Comprehensive Coverage is its ability to cover damages resulting from events other than accidents. This ensures a broader scope of protection for your vehicle.

  2. Financial Safeguard Against Theft and Vandalism: Cropseyville, like any other area, faces its share of theft and vandalism risks. Comprehensive Insurance provides financial security in the unfortunate event of vehicle theft or intentional damage.

  3. Peace of Mind in Natural Disasters: New York's susceptibility to severe weather, including storms and flooding, makes Comprehensive Coverage a valuable addition. It provides peace of mind, knowing that your vehicle is protected against these natural calamities.

Cons:

  1. Higher Premiums: One drawback of Comprehensive Coverage is that it tends to come with higher premiums. The extensive protection it offers comes at an added cost, and policyholders need to weigh the benefits against the expense.

  2. Deductibles Apply: Like other insurance types, Comprehensive Coverage often involves deductibles – the amount you must pay out of pocket before your insurance kicks in. Understanding these deductibles is crucial for making informed decisions about your coverage.

  3. Not Mandatory: While Comprehensive Coverage provides extensive protection, it's not a mandatory requirement in New York. Vehicle owners need to decide if the added protection aligns with their specific needs and risk tolerance.

In conclusion, Comprehensive Auto Insurance in Cropseyville, New York, offers a robust layer of protection against a range of non-collision events. Assessing its pros and cons in the context of Cropseyville's unique risks can help vehicle owners make informed decisions about their insurance coverage.

  • Harcourt v. General Acc. Ins. Co.

  • 419 Pa. Superior Ct. 155 (1992)

  • 615 A.2d 71

  • B. Timothy HARCOURT, D.C., Appellant, v. GENERAL ACCIDENT INSURANCE COMPANY, Omni-Med Consultants, Inc.

  • Superior Court of Pennsylvania.

  • Argued June 2, 1992.

  • Filed October 5, 1992.

  • *157 James J. Kutz, Harrisburg, for appellant.

  • Thomas E. Wood, Harrisburg, for Omni-Med, appellee.

  • Douglas B. Marcello, Harrisburg, for General Accident, appellee.

  • *158 Before MONTEMURO, KELLY and CERCONE, JJ.

  • CERCONE, Judge:

  • This is an appeal from a final order sustaining preliminary objections filed on behalf of General Accident Insurance Company ("General Accident") and Omni-Med Consultants, Inc. ("Omni-Med"). The order dismissed with prejudice a complaint filed by plaintiff/appellant B. Timothy Harcourt, D.C.[1] For the reasons explained below, we vacate the order of the trial court and reinstate appellant's complaint.

  • Certain relevant facts in the instant case have been correctly set forth by the trial court as follows:

  • Trial court opinion filed November 12, 1991 at 1-2. Omni-Med's denial notice to Dr. Harcourt properly informed him that he had a statutory right under the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa.C.S. § 1701 et seq., to request reconsideration of its decision. However, the *159 denial notice also contained the information that Omni-Med intended to inject a non-statutory pre-requisite into the reconsideration process: Dr. Harcourt was required to submit four hundred fifty dollars ($450.00), payable in advance, before his claim would be reconsidered. See Appellant's complaint, Exhibit A (letter from Omni-Med Consultants, Inc. dated January 14, 1991).

  • The certified record discloses that appellant lodged a timely request for reconsideration with Omni-Med. However, true to its letter of January 14th, the request remained unprocessed by Omni-Med since Dr. Harcourt didn't pay the processing fee which Omni-Med had no statutory authority to impose. When neither Omni-Med nor General Accident would act upon his request for reconsideration, appellant instituted the litigation which is the subject of the instant appeal by filing a complaint in the Court of Common Pleas for Dauphin County.

  • Appellant's complaint, docketed March 5, 1991, requested declaratory and equitable relief stemming from the alleged failure of Omni-Med and General Accident to follow the mandate of Pennsylvania's Motor Vehicle Financial Responsibility Law ("MVFRL"), supra. The complaint averred that the defendants/appellees had refused to comply with MVFRL's payment and peer review provisions. Appellant requested the trial court to direct the defendants/appellees to adhere to the requirements of MVFRL, provide him with an appropriate evaluation of his claim, and pay his provider fees during the pendency of the statutory review process. General Accident and Omni-Med responded by filing preliminary objections in the nature of a demurrer which were argued on October 2, 1991 before the Court of Common Pleas sitting en banc. The en banc panel of the Court of Common Pleas sustained the demurrer on November 12, 1991 and dismissed appellant's complaint with prejudice. The instant timely appeal followed.

  • Appellant's brief identifies four issues for our consideration:

  • Appellant's brief at 3 (emphasis added). Appellee General Accident has provided a brief which responds in a point by point fashion to the claims presented by appellant. Appellee Omni-Med has directly responded to only one of appellant's issues. However, Omni-Med has elected to raise two new points via its brief:

  • Brief filed on behalf of Omni-Med Consultants, Inc. at i. Appellant thereafter filed a reply brief which presents the following arguments:

  • Appellant's reply brief at i (emphasis added).

  • We shall first address Omni-Med's assertion that the Court of Common Pleas lacked subject matter jurisdiction to hear the complaint filed by Dr. Harcourt. Contrary to appellant's argument, the absence of a timely objection by Omni-Med to the trial court's subject matter jurisdiction is immaterial. An objection to jurisdiction over subject matter may never be lost by estoppel, consent, or waiver. Drummond v. Drummond, 414 Pa. 548, 551, 200 A.2d 887, 888 (1964). See also Civil Service Com'n v. Kuhn, 85 Pa.Commw. 85, 89, 480 A.2d 1327, 1329 (1984) (subject-matter jurisdiction cannot be conferred by the consent of the parties nor can it be waived as an issue). Although Omni-Med clearly has the right to challenge the court's jurisdiction, we find that Court *162 of Common Pleas exercised proper subject-matter jurisdiction in this case because of the nature of appellant's claim.

  • Since in this case the insurer, General Accident, and the peer review organization, Omni-Med, refused to act on appellant's petition for reconsideration, appellant petitioned the trial court for two types of relief: first, he sought a court order compelling General Accident and Omni-Med to comply with the statutory provisions of MVFRL; and second, he requested the court to provide declaratory relief in the form of an interpretation of 75 Pa.C.S. § 1797(b)(3) (Pending determination by a PRO).[3] Appellee Omni-Med has objected to the trial court's subject-matter jurisdiction on the grounds appellant has not exhausted his statutory remedies under MVFRL. We agree with Omni-Med that a statutory remedy is preferred over a common law remedy. 1 Pa.C.S. § 1504. Moreover, where there is a clear and adequate statutory remedy, that remedy is exclusive. See, e.g., Commonwealth Department of Environmental Resources v. Williams, 57 Pa. Commw. 8, 11, 425 A.2d 871, 872-73 (1981). In the instant case, however, we find that the governing statute provides no explicit "clear and adequate" remedy for the failure or deliberate refusal of either a provider or a PRO to abide by MVFRL's reconsideration provisions.

  • Here, the provider had exhausted his remedies under MVFRL: he had timely requested PRO reconsideration. Appellees' refusal to provide the statutory remedy left appellant with no recourse but to invoke the aid of a court of common pleas. To hold otherwise would be tantamount to ruling that our law permits an insurer to thwart the plain object of § 1797 by presenting a provider's claim to a PRO and then tabling any subsequent request for reconsideration of the PRO's ruling. Omni-Med's reading of the statute would deprive an aggrieved provider of any means to obtain redress in the event an insurer or a PRO either refused or neglected to perform the reconsideration plainly required by § 1797(b)(2). The Legislature can never have intended such a patently *163 absurd termination of a provider's rights. See Crosby by Crosby v. Sultz, 405 Pa.Super. 527, 541-42, 592 A.2d 1337, 1344-45 (1991) (courts should not construe statutes so as to promote or further absurd results).

  • Omni-Med also argues that appellant's claims are moot, at least as to Omni-Med. Careful consideration of this contention discloses that under the guise of a general "mootness" argument, Omni-Med is actually seeking dismissal as a party from the instant litigation. The linchpin of this argument is an averment that appellee Omni-Med Consultants, Inc. entered into an asset purchase agreement on November 8, 1991 by which it sold the assets of its PRO business to an allegedly unrelated entity fortuitously called "Omni-Medicorp, Ltd." Appellee Omni-Med therefore theorizes that appellant's claims are moot as to it since it is "no longer in the PRO business" and "any issue as to the manner in which it [formerly] conducted its business is moot." Appellee's brief at 10. Unfortunately, we can find no indication in the certified record that Omni-Med either presented this mootness claim to the trial court or petitioned to be removed as a defendant. Issues not raised in the lower court are waived and cannot be raised for the first time on appeal. Pa.R.A.P., Rule 302(a), 42 Pa.C.S.

  • Having disposed of these initial procedural questions, we may now address appellant's substantive claim: that the trial court erred in granting appellees' preliminary objections in the nature of a demurrer. In support of this contention, appellant has presented three hypotheses. In the first and second instances, appellant claims (in the alternative): (1) that it was error on the part of the trial court to grant appellee's preliminary objections in the nature of a demurrer because MVFRL requires the initial determination of a PRO to be performed by a medical practitioner licensed in the same profession as that of the treating practitioner whose services are subject to the reviewing process; or (2) that Insurance Department regulations which were implemented after the trial court's decision was reached mandate initial PRO review by a medical practitioner licensed identically to the provider. Appellant *164 also argues that it was error for the trial court to conclude that an automobile insurance company may ignore the thirty day limitation period provided by 75 Pa.C.S. § 1797(b)(3) during which the carrier may challenge a provider's treatment.

  • Our scope of review from an order sustaining preliminary objections in the nature of a demurrer and dismissing a complaint is plenary. Cavaliere v. Duff's Business Institute, 413 Pa.Super. 357, 364, 605 A.2d 397, 400 (1992). The role of this court is to ascertain "whether the trial court correctly determined that, taking as true all properly pleaded material facts and disregarding all pleaded conclusions of law, under no circumstances will the law permit recovery on the complaint." Id. (citing Pawlowski v. Smorto, 403 Pa.Super. 71, 588 A.2d 36 (1990) and Doe v. Dyer-Goode, 389 Pa.Super. 151, 566 A.2d 889 (1989), allocatur denied, 527 Pa. 587, 588 A.2d 509 (1990)).

  • Bash v. Bell Telephone Co., 411 Pa.Super. 347, 354-55, 601 A.2d 825, 828-29 (1992) (citations omitted).

  • Appellant has advanced alternative theories in support of his position that he was entitled to review by a member of his own profession during the initial phase of the PRO process. *165 The thrust of his first argument is that the peer review mechanism mandated by 75 Pa.C.S. § 1797 cannot be interpreted in isolation, but can be properly understood only when read in pari materia with § 1702 which defines the phrase "Peer Review Organization." Appellant is quite correct that § 1797 itself contains no discussion as to the professional qualifications required of the "peer" who performs the initial review:

  • 75 Pa.C.S. § 1797(b)(1). However, inspection of MVFRL demonstrates that the Legislature has supplied the pertinent explication for § 1797 via § 1702:

  • Id. § 1702 (emphasis added). This definition clearly requires that a PRO must include representation from the same profession under review whenever a PRO is employed in connection with any section of the Motor Vehicle Financial Responsibility Law. It would be absurd to interpret this statutory provision *166 to mean that the PRO need only retain such qualified individuals as "window-dressing" but need not employ them in the actual review process. As previously stated, courts should not construe statutes so as to promote absurd results. Crosby by Crosby v. Sultz, 405 Pa.Super. at 541-42, 592 A.2d at 1344-45.

  • Appellant has correctly noted that the proper distinctions between the initial and reconsideration phases of the PRO process concern the status difference between a reviewer who is a member of the provider's "profession" and one who is a member of the provider's professional "specialty." MVFRL requires that the initial PRO evaluation need only be performed by a member of the provider's profession. However, any reconsideration conducted under the auspices of § 1797 must be handled by a person who belongs not only to the same profession, but is also a practitioner in the same specialty as the provider.

  • 75 Pa.C.S. § 1797(b)(2) (emphasis added). While we agree with General Accident that the Legislature provided no explicit requirement for a particular form of initial PRO evaluation in § 1797(b) itself, we cannot agree that this constitutes a failure on the part of the Legislature. Simply put, the definitions of § 1702 control peer review under § 1797(b). That § 1797(b)(2) explicitly sets forth a more stringent form of evaluation for the reconsideration phase cannot be interpreted to mean that the initial PRO phase is unregulated in light of the clear language of § 1702, supra.

  • Appellant and appellee General Accident have presented lengthy and complex arguments regarding the proper professional qualifications which a PRO reviewer must possess. *167 However, we need not go into detail regarding these claims because it is beyond cavil that words and phrases in a statute must be construed according to their common and approved usage. 1 Pa.C.S. § 1903(a). The term "profession" is defined by Webster as "the collective body of persons engaged in or practicing a particular calling or vocation." Webster's New Universal Unabridged Dictionary 1437 (J. McKechnie 2d ed. 1983). "Specialist," however, has a much more restrictive definition. A specialist is "a person who devotes himself [or herself] to a particular branch of a profession, art, or science; a person who has studied and acquired specific knowledge on some particular subject; as, oculists and aurists are specialists as regards surgery." Id. at 1741. In Pennsylvania, chiropractic licensure and practice is regulated by the Chiropractic Practice Act ("the Act"), 63 P.S. § 625.101 et seq. The provisions of the Act explicitly acknowledge that chiropractic is a profession which is further subdivided into specialty practices. Under Pennsylvania law, a practitioner of chiropractic may hold himself out as a "specialist," but only after obtaining postgraduate certification in the avowed specialty. Id. § 625.506(a)(17). See also id. § 625.301 (defining the term "chiropractor").

  • Applying these legal definitions to the present case, it emerges that chiropractors, the collective body of persons engaged as chiropractic practitioners, are exponents of a profession; but without postgraduate certification, chiropractors are not "specialists." Under any reasonable interpretation of §§ 1702 and 1797(b) of MVFRL, appellant was entitled to an initial review by a member of his own profession, although not to review by a member of a chiropractic specialty, when the case was first submitted to the PRO. We therefore conclude that appellant was entitled to consideration by a chiropractor during the initial phase of the PRO review.[4]

  • *168 Appellant's final allegation is that the trial court erred in permitting General Accident to willfully disregard the thirty day limitation period during which an insurance carrier may challenge a provider's treatment without first paying the provider. Appellant believes that this error was compounded when the trial court disregarded the fact that the insurance carrier and the PRO acted in concert to impose non-statutory hurdles to the review/reconsideration process in the form of a $450 fee levied against Dr. Harcourt before Omni-Med would reconsider the claim. From the pleadings in the certified record, it appears to be appellees' position that appellant's request for reconsideration was untimely filed because he refused to pay Omni-Med's reconsideration fee.

  • In this situation, we are inclined to agree with certain recent comments by the Honorable R. Stanton Wettick of the Court of Common Pleas of Allegheny County which are highly apropos of the instant case:

  • Lehman v. State Farm Insurance Companies, 140 P.L.J. 78, 82 (1992). We can find no statutory provision in MVFRL which supports Omni-Med's claim for a reconsideration fee to *169 be paid by the medical provider.[5] However, MVFRL does contain the following language dispositive of appellant's challenge:

  • 75 Pa.C.S. § 1797(b)(3). We agree with appellant that section 1797(b)(3) clearly requires an insurance carrier to pay the provider any disputed amounts for treatment which has not been challenged until thirty-one (31) or more days after the carrier receives the bill for the treatment. Under the plain terms of subsection (b)(3), an insurer must pay a provider if the insurer has not commenced the PRO review process within thirty days.

  • The trial court actually agreed with appellant's interpretation of the statute. However, the trial court considered the point to be moot because the initial PRO review favored General Accident:

  • Trial court opinion at 6-7.[6] We find the trial court's mootness ruling inapplicable to the present case as the initial resolution of appellant's claim was reached via a flawed and faulty process which cannot be permitted to stand. It is irrelevant that a plaintiff may tack an interest charge onto his award if he ultimately achieves a favorable result under the statute's reconsideration provision. The plain terms of subsection (b)(5) required General Accident to pay Dr. Harcourt for the treatment rendered to Ms. Wagner during the initial review *171 process if the matter was not referred to the PRO within thirty days of Dr. Harcourt's billing.

  • We see no indication in the certified record for the instant case that appellant was ever notified that General Accident had commissioned a peer review until he received the notice of the unfavorable evaluation by Omni-Med. The certified record is silent regarding the date on which General Accident referred the matter to Omni-Med. Since the record certified to this court provides no information concerning this factual matter crucial to resolution of appellant's third claim, we must remand the case to the trial court so that it may determine the date on which General Accident submitted appellant's claim to Omni-Med for initial PRO consideration. If this referral occurred more than thirty days after Dr. Harcourt originally submitted his claim, then he is entitled to payment of his fee plus interest as of the original submission date. See 75 Pa.C.S. § 1797(b)(3). In this event, the trial court shall enter an order directing General Accident to pay Dr. Harcourt the total amount of his claim plus the applicable interest.[7] While the question of General Accident's initial referral date is before the trial court, Omni-Med may petition for removal as a defendant in this litigation on grounds of mootness.

  • After the trial court has conducted the necessary fact-finding and made its ruling regarding Dr. Harcourt's right to payment under § 1797(b)(3), General Accident may elect either to pay Dr. Harcourt and let the matter rest, or in the alternative, may proceed with a new peer review. Should General Accident initiate a peer review process on remand, Dr. Harcourt's claim may only be referred to a new peer review organization which is unconnected in any way with appellee Omni-Med Consultants, Inc. The new PRO may not be a successor in interest to Omni-Med Consultants, Inc. If General Accident elects to pursue a peer review, the matter shall be submitted for an initial review to be conducted by a *172 chiropractor in accordance with the foregoing opinion.[8] Should the initial PRO determination favor General Accident, Dr. Harcourt will have the right to request reconsideration before a chiropractic specialist. Any reconsideration fee charged may not exceed the initial fee charged by the PRO to General Accident. The reconsideration fee must be paid by General Accident, but ultimately shall be borne by the party against whom the reconsideration determination is made.

  • The order of November 13, 1991 is vacated and appellant's complaint is reinstated. The case is remanded with instructions. Jurisdiction is not retained.

  • [1] An order which sustains preliminary objections and dismisses a complaint is, of course, both final and immediately appealable. See Bash v. Bell Telephone Co., 411 Pa.Super. 347, 601 A.2d 825 (1992).

  • [2] "Act 6," P.L. 11, No. 6 enacted February 7, 1990, effectuates extensive modifications to the Motor Vehicle Financial Responsibility Law which comprises Chapter 17 of the Motor Vehicle Code. See 75 Pa.C.S. § 1701 et seq. At issue in the instant appeal are the medical cost containment savings provisions of Act 6 "which limit permissible charges by health care providers for the treatment or services rendered to automobile accident victims ... and provide for the utilization of peer review organizations (PROs) by property and casualty insurers for the purpose of evaluating the quality and medical necessity of treatment." 21 Pa.Bull. 5601 (November 30, 1991).

  • [3] Section 1797(b)(3) is set forth infra in conjunction with our discussion and resolution of appellant's allegations of trial court error.

  • [4] Having reached the above conclusion, we need not consider appellant's contentions regarding certain federal peer review regulations or those contained in Pennsylvania's Peer Review Protection Act, 63 P.S. § 425.1 et seq., which allegedly support appellant's interpretation of MVFRL. Nor will we address the merits of appellant's alternative argument concerning the final regulations promulgated by the Insurance Department.

  • [5] During the comment period prior to promulgation of final administrative regulations by the Insurance Department, appellee Omni-Med recommended that the requesting party (presumably the medical provider in most instances) should bear the cost of PRO reconsideration. 21 Pa.Bull. 5606 (November 30, 1991). This was not the position actually adopted by the Department. The final administrative regulations provide that the insurance carrier "shall make up-front payment for reconsideration to the PRO, but that the losing party shall ultimately pay for the reconsideration." Id.; codified at 31 Pa.Code § 69.52(h). The Insurance Department established no fee schedule or formal fee structure for reconsideration because MVFRL contemplates that insurance carriers and PROs will contract jointly for the purpose of PRO review. 21 Pa.Bull. 5606. As a cost control measure, the charge for reconsideration may not exceed the charge for the initial review paid by the insurance carrier. Id.; 31 Pa.Code § 69.52(h). It is an unfortunate fact that the final administrative regulations simply were not promulgated by the Insurance Department in time to guide Omni-Med in its approach to Dr. Harcourt's claim.

  • [6] The subsections to which the trial court refers contain the following language:

  • PRO determination in favor of provider or insured. If a PRO determines that medical treatment or rehabilitative services or merchandise were medically necessary, the insurer must pay to the provider the outstanding amount plus interest at 12% per year on any amount withheld by the insurer pending PRO review.

  • 75 Pa.C.S. § 1797(b)(5);

  • Determination in favor of insurer. If it is determined by a PRO or court that a provider has provided unnecessary medical treatment or rehabilitative services or merchandise or that future provision of such treatment, services or merchandise will be unnecessary, or both, the provider may not collect payment for the medically unnecessary treatment, services or merchandise. If the provider has collected such payment, it must return the amount paid plus interest at 12% per year within 30 days.

  • Id. § 1797(b)(7) (emphasis added). Both the trial court and appellees seem to misunderstand the import of subsection (b)(7) as they appear to believe that the provider would be under no obligation to return payments made by the insurer prior to a determination unfavorable to the provider.

  • [7] Should a PRO ultimately determine that Dr. Harcourt's services were medically unnecessary, he will be required to return this sum to General Accident. See 75 Pa.C.S. § 1797(b)(7).

  • [8] This court is cognizant of the fact that the Insurance Department's administrative regulations directly apply only to insurer payments to providers for services rendered on and after November 30, 1991. 31 Pa.Code § 69.2. However, the parties to the instant litigation need no longer "operate in the dark" as to the proper construction and effect of 75 Pa.C.S. § 1797 because their peer review process may be fully informed by reference to the final administrative regulations set forth at 31 Pa.Code § 69.52.

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