2 N.Y.3d 560 (2004)
When interpreting the term “board certified” in the context of Workers’ Compensation Law § 137 (3) (a), it refers to certification by a medical specialty board recognized by either the American Board of Medical Specialties (ABMS) or the American Osteopathic Association (AOA), not certification by the Workers’ Compensation Board itself.
Summary
This case concerns the interpretation of “board certified” under New York’s Workers’ Compensation Law, specifically regarding who is authorized to perform independent medical examinations (IMEs). The Workers’ Compensation Board (WCB) defined “board certified” as certification by a medical specialty board recognized by the ABMS or AOA. Several physicians, licensed in New York but not certified by ABMS or AOA-recognized boards, challenged this interpretation. The Court of Appeals held that “board certified” refers to certification by a medical specialty board, upholding the WCB’s regulation as rational and consistent with the statute’s purpose of ensuring quality in IME providers.
Facts
Petitioners, New York State licensed medical doctors, previously conducted IMEs. The WCB denied their requests to continue performing IMEs because they lacked certification from a medical specialty board recognized by the ABMS or AOA. Some petitioners were certified by other specialty boards, and some held a “C” rating from the WCB, indicating competence based on experience.
Procedural History
Petitioners filed CPLR article 78 proceedings to annul the WCB’s regulation requiring ABMS or AOA certification for IME physicians. Supreme Court granted the petition in part, holding that “board certified” referred to WCB certification. The Appellate Division affirmed. The Court of Appeals then reversed the Appellate Division’s decision.
Issue(s)
1. Whether the term “board certified” in Workers’ Compensation Law § 137 (3) (a) means certification by a medical specialty board or by the Workers’ Compensation Board (WCB)?
2. Whether the WCB’s regulations appropriately defined “board certified” as certification by a medical specialty board recognized by either the American Board of Medical Specialties (ABMS) or American Osteopathic Association (AOA)?
Holding
1. Yes, because a plain language reading of the statute supports the conclusion that “board certified” means certification by a medical specialty board, as the phrase is a term of art typically understood to refer to approval by a designated group of professionals.
2. Yes, because the WCB is authorized to adopt reasonable rules consistent with the Workers’ Compensation Law, and these regulations are rational and relate to the goals of the Injured Workers’ Protection Act.
Court’s Reasoning
The Court reasoned that the phrase “board certified” is a term of art commonly understood to mean certification by a medical specialty board. The Court noted that the Legislature has used the term “board certified” in other statutes to refer to a medical specialty board. It rejected the argument that the word “board” must have the same meaning throughout the provision, explaining that context matters. The Court stated, “board can have a different meaning on its own than it does as part of the phrase board certified.”
The Court found that requiring certification by ABMS or AOA-recognized boards was rational because it “promotes the purpose of the statute since it provides a greater level of quality assurance as the physicians authorized to perform IMEs have attained a certain degree of professional competence as recognized by the certifying boards.” The Court emphasized the WCB’s authority to adopt reasonable rules and regulations, stating, “This Court reviews administrative regulations to determine whether they are rational and to ensure that they are not arbitrary or capricious.”
Regarding the legislative intent, the Court implicitly found that the Injured Workers’ Protection Act aimed to improve the quality and reliability of IMEs. Requiring certification by recognized specialty boards aligned with this goal.
No dissenting or concurring opinions were mentioned.