e-Journal Summary

e-Journal Number : 77573
Opinion Date : 06/09/2022
e-Journal Date : 06/13/2022
Court : Michigan Court of Appeals
Case Name : Meemic Ins. Co. v. Christian Care Ministry, Inc.
Practice Area(s) : Healthcare Law Insurance
Judge(s) : Yates, Ronayne Krause, and M.J. Kelly
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Issues:

Coordination of coverage; MCL 500.3109a; Farm Bureau Gen Ins Co v Blue Cross Blue Shield of MI; Effect of the Health Care Sharing Ministries Freedom to Share Act; MCL 550.1867(b), (c), & (g); Whether coordination of coverage under MCL 500.3109a & health care sharing on a voluntary basis under MCL 550.1867 can coexist; “Other health & accident coverage”; Jarrad v Integon Nat’l Ins Co; No-Fault Act (NFA)

Summary

The court held that the trial court did not err by granting defendant, a voluntary health care sharing ministry, summary disposition of plaintiff-insurer’s claim seeking to deem defendant responsible for plaintiff’s insured’s (non-party Vanderlinden) medical expenses under a coordination-of-coverage provision in his auto policy. Plaintiff paid PIP benefits to Vanderlinden after he was injured in an auto accident. It then filed this action contending defendant was obligated by MCL 500.3109a and plaintiff’s coordination-of-coverage policy language to bear the primary responsibility for Vanderlinden’s medical expenses. The trial court granted summary disposition for defendant, finding defendant’s health care sharing program, Medi-Share, qualifies as a health care sharing ministry and, thus, “is neither an insurer nor subject to the insurance laws of the State of Michigan, including coordination of coverage under MCL 500.3109a.” On appeal, the court concluded that “allowing coordination of coverage with what a health care sharing ministry provides is a bridge too far.” It found no basis “to characterize what a health care sharing ministry provides to its participants as ‘other health and accident coverage’ for purposes of coordination of coverage under the” NFA. “Our Legislature placed its imprimatur upon health care sharing ministries operating entirely outside the insurance system and providing assistance to the participants on a purely voluntary basis.” As such, “it should come as no surprise that health care sharing ministries do not furnish ‘other health and accident coverage’ within the contemplation of the” NFA for purposes of coordination of coverage under MCL 500.3019a. Affirmed.

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