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A Better Partnership
December 11, 2014

COA: Healthcare providers have standing to sue no-fault insurers for PIP benefits

The Court of Appeals concluded that healthcare providers have standing to sue insurers for personal injury protection (PIP) benefits under the no-fault act.  The Court therefore affirmed the trial court’s denial of the defendant-insurer’s motion for summary disposition in Wyoming Chiropractic Health Clinic, PC v. Auto-Owners Ins. Co., No. 317876
Wyoming Chiropractic, a healthcare provider, provided care to insured individuals, and then sued Auto-Owners, their insurer, for the purpose of obtaining PIP benefits under the personal protection benefits provision of the no-fault act.  Under the no-fault act, “[p]ersonal protection insurance benefits are payable to or for the benefit of an injured person.”  MCL 500.3122 (emphasis added).  The Court of Appeals previously established in Munson Med Ctr v Auto Club Ins Ass’n, 218 Mich App 375, 381; 554 NW2d 49 (1996), that a healthcare provider has the “right to be paid for the injureds’ no-fault medical expenses,” and clarified in Mich Head & Spine Inst, PC v State Farm Mut Auto Ins Co, 299 Mich App 442, 448 n 1; 830 NW2d 781 (2013), that a healthcare provider has a direct cause of action to sue an insurer for PIP benefits under the no-fault act. Based on these precedents, the Court concluded that healthcare providers have standing to bring a claim against insurers for PIP benefits under the no-fault act.  The Court of Appeals further noted that allowing a healthcare provider to have standing to sue an insurer for PIP benefits helps to achieve the no-fault act’s public policy goals by expediting the payment process and preventing inequitable payment structures.

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