On Oct. 21, 2025, a judge in Florida issued a groundbreaking decision in Complete Care v State Farm, 25-CA-1063. It concerns a fact pattern that many chiropractic doctors have faced wherein an insurer, such as State Farm or Allstate, decides to simply stop paying all claims submitted by a healthcare provider.
The Case Details
On April 3, 2025, State Farm decided to stop paying all claims, no matter how meritorious, submitted by Complete Care, amounting to over $600,000 a month, due to alleged fraud by Complete Care. (Complete Care is a network of 30 rehab clinics that include chiropractic as a primary form of care.) The alleged fraud was “the delayed collection of deductibles and coinsurance from their patients.”
Complete Care pointed out that it requires every patient to sign a written contract that each patient is liable for deductibles/co-pays and collects 86% of them, a better percentage than most clinics.
Judge Paul Huey, when faced with these facts, found that State Farm had issued a private mandatory injunction against Complete Care without getting a court’s approval and did so without a factual basis. He found that “State Farm needs probable cause before it can trample a citizen’s rights.”
State Farm had sent letters to every Complete Care patient insured by State Farm, stating that State Farm would not pay their claim because State Farm was suing Complete Care (the “Breach Letters”). Paradoxically, these Breach Letters by State Farm caused some patients to not pay their copays.
The judge then did something unique. In an unprecedented ruling, he issued an injunction against State Farm 1) stopping State Farm’s private injunction of not paying Complete Care claims; 2) barring State Farm from sending out any further Breach Letters encouraging patients to not pay their copays; 3) requiring State Farm to send a letter to everyone who got the Breach Letter advising them to pay their copays/deductibles; and 4) requiring State Farm to pay all of Complete Care’s outstanding claims.
Why This Matters
The court treated the private injunctions State Farm and Allstate have been known to issue frequently as illegal. This decision is a legal tool all healthcare providers, including chiropractic doctors, can use to fight this type of abuse. While Complete Care is better funded to fight this battle than most individual chiropractic doctors, all DCs can band together through their state and national associations using this legal tool.
Recent laws in New Jersey and California represent a disturbing trend that will negatively impact a practice’s ability to collect monies from patients, as well as expose them to significant penalties if the practice does not follow the mandatory guidelines to a T. Please be aware that a similar law may be coming to your state. The time to act is before the law is passed.
Each year, ICD-10-CM is updated on Oct. 1. For 2026, there are 74,179 total codes, with 487 additions, 28 deletions and 38 revisions. Code changes are based on date of service, not the claim submission date. Services performed on/after Oct. 1 must use the new codes. While no changes affect the common spinal or extraspinal codes most frequently used by DCs, several updates may still affect your claims – particularly for comorbidities, referred pain, or trauma cases.
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Southern California University of Health Sciences has entered into an agreement with Pacific College of Health and Science whereby PCHS’ San Diego and Chicago campuses – including students, faculty, staff, and academic programs – will join SCU effective May 2026, pending regulatory approval. Founded in 1986 as Pacific College of Oriental Medicine, PCHS is not only the largest acupuncture / herbal medicine school in the U.S., but also offers integrative health curriculum in holistic nursing and massage therapy.
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