Supreme Court Limits Andary, Determines Provider Claims Controlled by Law in Effect When Medical Service Rendered

NFN re Spine Specialists v MemberSelect by David Kinzer 4-16-25Spine Specialists stands for the proposition that a provider’s claim for specific medical expenses accrues at the time the expense is incurred and is therefore governed by the law in effect at the that services were provided. The case corrects a common misunderstanding of Andary v USAA Cas Ins Co, 512 Mich 207 (2023) as suggesting that all claims are governed by the law in effect at the time of the underlying accident, including provider claims. Instead, Spine Specialists demonstrates that courts must distinguish between the scope of benefits available to injured persons, which vests at the time of injury, and a provider’s right to compensation for specific medical expenses, which vests at the time the expense is incurred.