skip to main content


State Responds to Auto No-Fault Payment Delays

November 22, 2021

Question: I recently treated a few patients injured in auto accidents. Getting paid for these services has never been easy. These latest claims, however, have been extremely difficult. The no-fault insurer takes a long time to respond, requests additional information, and questions the information I provide in response to its requests. Is anything being done about this?

Answer: Apparently, Michigan’s Department of Insurance and Financial Services (DIFS) has received a number of complaints about this recently. I response, on Sept. 22. 2021, DIFS issues Bulletin 2021-36-INS, and on Oct. 5, 2021 issues Bulletin 2021-36-INS.

In the first of these bulletins, DIFS acknowledges that many health care providers are experiencing delays in payment due from no-fault auto insurance benefits. This bulletin reminds insurers that:

  • Per MCL 500.3142, bills are overdue if not paid within 30 days after the no-fault insurer has received “reasonable proof of the fact and of the amount of loss its insured has sustained” (i.e., a provider’s bill).
  • Per MCL 500.3142(4), if a bull is provided to the no-fault insurer more than 90 days after the service is provided, the np-fault insurer then has 90 days to pay before the bill is considered overdue.
  • Per MCL 500.3142(4), overdue payments bear interest at a rate of 12% per annum. DIFS further states no-fault insurers and providers should attempt to resolve billing and coding disputes informally and that no-fault insurers should provide reasonable assistance to ensure that their “billing and coding” requirements are clearly conveyed to providers and their billers.

Finally, this bulletin informs providers that when a no-fault insurer denies payment claiming that a service provided (e.g., lacks medical necessity) or the fee charges was inappropriate, a provider appeal may be filed with DIFS’ Utilization Review program. Providers are strongly encouraged to review DIFS’ Health Care Provider’s Guide to Michigan’s Auto Insurance Utilization Review Process for guidance on how to go about filing an appeal.

Read the complete Q&A in the Journal of the Michigan Dental Association on page 20.

About the author:

Daniel J. Schulte answer questions about health care lawDaniel J. Schulte has more than 25 years of experience helping clients solve tough problems and capitalize on opportunities that require a blend of business and legal expertise. His practice focuses on addressing the legal, business, licensing, and regulatory challenges of health care professionals, organizations, and facilities. Dan understands how legal issues impact business objectives and, as a result, offers his clients practical, results-oriented advice. He is a Certified Public Accountant, former managing partner and current executive committee member of the firm. Dan also serves as co-chair of the firm’s Health Care Practice Group.



Other posts to consider:


Practice Areas