Victoria Taylor v. Farmers Insurance Company
368754
Mich. Ct. App.Apr 14, 2025Background
- Victoria Taylor was injured in a car accident and received treatment from DMC from December 5-8, 2019, accruing charges of $113,072.25.
- DMC billed Medicaid, which paid $6,202.78 as a conditional payment, after which DMC marked Taylor's bill as satisfied ($0 owed by Taylor).
- Taylor later made a claim for no-fault insurance benefits, which was assigned to Farmers Insurance by the Michigan Automobile Insurance Placement Facility.
- The dispute centered on whether Farmers was obligated to pay the full amount of DMC’s charges or only the amount paid by Medicaid.
- The trial court granted partial summary disposition to Farmers, limiting its liability to the amount paid by Medicaid; Taylor appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What expenses are "incurred" under MCL 500.3107(1)(a)? | Taylor incurred full original charges regardless of Medicaid's pay. | Farmers only responsible for amount satisfied by Medicaid. | Only the amount paid by Medicaid was "incurred" by Taylor. |
| Liability after provider accepts Medicaid payment | Taylor incurred whole billed amount; Medicaid payment didn't satisfy | Acceptance of Medicaid payment satisfies bill; Taylor owes $0 | Acceptance of Medicaid payment satisfied Taylor's legal bill. |
| Application of federal/state law on seeking additional pay | Federal law allows provider to seek more from no-fault insurers | Providers barred from balance/substitute billing after Medicaid | Declined to rule on legality of further collection in this case. |
| Medical provider's rights after insurer pays | DMC can seek more from insurer after Medicaid payment | DMC bound by acceptance of Medicaid; can't collect more | No evidence DMC seeks more payment; case limited to record facts. |
Key Cases Cited
- Shanafelt v. Allstate Ins. Co., 217 Mich. App. 625 (explanation that medical expenses are incurred when a patient becomes liable for them)
- Bombalski v. Auto Club Ins. Ass’n, 247 Mich. App. 536 (held that only the amount paid and accepted in satisfaction of a medical bill is incurred)
- Duckworth v. Continental Nat’l Indemnity Co., 268 Mich. App. 129 (expenses not incurred for free medical services)
- Farm Bureau Gen. Ins. Co. v. Blue Cross Blue Shield of Michigan, 314 Mich. App. 12 (if insured has no responsibility for a bill, the expense is not incurred)