Provider Claims Barred When Underlying Claimant Is Statutorily Disqualified
In Labser PLC and Northland Radiology, Inc. v Farmers Insurance Exchange, the Court of Appeals held in a published decision that a healthcare provider cannot recover PIP benefits under MCL 500.3112 where the injured person is statutorily disqualified from PIP coverage. Although MCL 500.3112 gives providers an independent direct cause of action, that right extends only to treatment for injuries actually covered by PIP insurance. Because Simpson was a constructive owner of the uninsured vehicle and therefore disqualified under MCL 500.3113(b), the providers had no recoverable PIP claim.
In Labser PLC and Northland Radiology, Inc. v Farmers Insurance Exchange, the Court of Appeals held in a published decision that a healthcare provider cannot recover PIP benefits under MCL 500.3112 where the injured person is statutorily disqualified from PIP coverage. Although MCL 500.3112 gives providers an independent direct cause of action, that right extends only to treatment for injuries actually covered by PIP insurance. Because Simpson was a constructive owner of the uninsured vehicle and therefore disqualified under MCL 500.3113(b), the providers had no recoverable PIP claim.
| labser_v_farmers_–_provider_pip_claim_barred_by_claimant_disqualification.pdf |