29 April 2022

Michigan Court of Appeals Reiterates: ‘1 Year Means 1 Year’ For Medical Providers Awaiting No-Fault Payments

The Michigan Court of Appeals issued an opinion on March 24, 2022 that serves as a reminder and a warning to medical providers awaiting payment on no-fault claims:  1 year means 1 year.

The case, Archangel Physical Therapy, LLC v State Farm, involved a dispute over no-fault benefits owing to a medical provider.  Archangel had provided physical therapy services to a State Farm insured for injuries stemming from a motor vehicle accident.  It later sought payment from State Farm for those services.  In response, State Farm eventually sought to “negotiate directly” with Archangel regarding payment.  During the course of those negotiations, more than one year elapsed since Archangel’s dates of service for which it was seeking payment.  When the negotiations ultimately failed to reach agreement, Archangel sued.  State Farm defended the lawsuit on the basis that the dates of service for which payment was sought were barred under the “one-year-back” rule – a provision in the no-fault law that requires a provider to file a lawsuit to recover benefits within one year of the date of service at issue to avoid having its claim barred.  The lower court agreed with State Farm and dismissed Archangel’s claim.

On appeal, a three-judge panel of the Court of Appeals agreed that the claim was barred by the one-year-back rule.  Despite the fact that State Farm had engaged in negotiations with Archangel over the bills, the Court upheld the ruling in favor of State Farm because there was no evidence that “State Farm made assurances that it would pay or settle Archangel’s claims or that State Farm induced Archangel to delay filing suit.”

This case serves as a reminder to medical providers seeking payment of their no-fault claims:  1 year means 1 year.  Failure to file a lawsuit on an overdue claim within 1 year of the date of service at issue risks losing payment.  Automobile insurers are well-aware of these 1 year timelines and, in our universal experience, will oppose payment of claims that are untimely in Court.

If you have questions about this or any other medical reimbursement issue, please contact any one of our provider reimbursement counsel at