Court of Appeals Affirms Expansive Interpretation of No Future Assignments Rule

Bronson Health Care Group, Inc v USAA Casualty Ins Co, et al., ___ Mich App ___; ___ NW2d ___ (2020) (Docket No. 351050) affirmed that the “no future assignment” provision of MCL 500.3143 applies to any no-fault benefit incurred after the execution of a purported assignment.

In making this decision, the Court rejected the proposition that an assignment could survive this rule so long as it was executed contemporaneous with, or immediately prior to, the treatment which was the subject of the assignment being actually rendered. Importantly, the treatment in Bronson related to an emergency department visit which was uninterrupted from the signing of the assignment to the completion of treatment on that particular date of service, but nevertheless still fell within the provisions of the rule.

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