The Michigan Supreme Court issued a decision in *Spine Specialists of Michigan PC v. MemberSelect Insurance Company*, addressing a healthcare provider's efforts to collect personal protection insurance benefits for medical care provided to an auto accident victim. The case, decided April 1, 2025, involves complex issues surrounding Michigan's no-fault insurance law and recent legislative changes affecting claim filing deadlines.
Spine Specialists of Michigan PC filed suit in Macomb Circuit Court against MemberSelect Insurance Company seeking payment for medical care provided to Jeremy Woods, the insurance company's insured. Woods was injured in an automobile collision in 2017 and subsequently received medical treatment from the plaintiff healthcare practice. Following his treatment, Woods assigned his right to receive personal protection insurance benefits to Spine Specialists, authorizing the medical practice to pursue payment directly from his insurance carrier.
Despite the assignment, MemberSelect Insurance Company refused to pay the medical bills submitted by Spine Specialists. The insurance company's refusal to pay prompted the healthcare provider to file a lawsuit seeking to recover the unpaid medical expenses through the courts.
The central legal issue in the case revolves around Michigan's one-year-back rule, codified in MCL 500.3145. This provision requires claimants to file legal action to recover no-fault insurance benefits within one year of when the medical services were rendered. MemberSelect moved for summary disposition, arguing that the amounts sought by Spine Specialists were barred by this one-year limitation period.
The case became more complex due to legislative changes made to Michigan's no-fault insurance law. In 2019, the Michigan Legislature amended MCL 500.3145 by adding subsection (3), which created a tolling provision that extends the one-year filing deadline under certain circumstances. This amendment became effective on June 11, 2019, creating a distinction between medical services rendered before and after that date.
Trial Court Judge Edward A. Servitto granted MemberSelect's summary disposition motion regarding Spine Specialists' claims for medical services rendered before the 2019 amendment became effective. The court found that these pre-amendment claims were indeed barred by the original one-year-back rule. However, Judge Servitto denied the insurance company's motion regarding claims for services provided after June 11, 2019, recognizing that the new tolling provision might apply to these later claims.
The case highlights the ongoing challenges healthcare providers face in collecting payment for medical services provided to auto accident victims under Michigan's no-fault insurance system. Healthcare providers often rely on assignment agreements with patients to pursue payment directly from insurance carriers, but they must navigate complex statutory deadlines and procedural requirements.
The 2019 amendments to Michigan's no-fault insurance law represented the legislature's attempt to address some of the systemic issues within the state's auto insurance system. The addition of the tolling provision in MCL 500.3145(3) was designed to provide more flexibility in certain circumstances where the strict one-year deadline might create unfair results for legitimate claimants.
This case demonstrates the practical impact of these legislative changes on healthcare providers and insurance companies. The Supreme Court's involvement suggests the legal questions presented were significant enough to warrant review at the state's highest judicial level, potentially affecting how similar disputes are resolved throughout Michigan.
The decision could have broader implications for healthcare providers across Michigan who treat auto accident victims and rely on no-fault insurance payments. The court's interpretation of the amended statute and its application to different time periods for medical services will likely influence how providers structure their billing and collection practices going forward.
For insurance companies, the ruling provides guidance on how to evaluate claims under the modified statutory framework and may affect their strategies for defending against lawsuits filed by healthcare providers seeking payment for medical services.
The case also underscores the importance of timing in no-fault insurance litigation. The distinction between pre-amendment and post-amendment services creates different legal standards that both healthcare providers and insurance companies must carefully consider when pursuing or defending claims.
As Michigan continues to refine its no-fault insurance system, cases like *Spine Specialists* serve as important precedents for interpreting the complex interplay between statutory deadlines, legislative amendments, and the practical realities of healthcare billing and insurance coverage. The Supreme Court's decision will likely be closely studied by attorneys representing both healthcare providers and insurance companies in similar disputes.