I’m Just A Bill: Insurer’s Receipt of Medical Bill Alone Not Enough to Give Proper Notice of Claim

As held by Covenant, SEMSH did not have a statutory cause of action for PIP benefits from Defendant but could recover PIP benefits if the insured (Toma) assigned his rights to SEMSH. The Court of Appeals noted that Auto Club would only be on notice that SEMSH had a “claim” under MCL 500.3112 if SEMSH provided Defendant with notice of the assignment of rights SEMSH executed with Toma. Thus, Toma’s medical bill from SEMSH, without more, did not put Auto Club on notice that SEMSH had a “claim” under MCL 500.3112.

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