Michigan's insurance regulator has issued new guidance for no-fault auto insurers handling home health care claims.
On April 24, 2026, the Department of Insurance and Financial Services (DIFS) issued Bulletin 2026-15-INS in response to a Michigan Court of Appeals decision that clarifies how insurers reimburse home health aide and skilled nursing care under the state's no-fault system. The ruling, handed down on October 20, 2025, in West Michigan Home Care Services, Inc v. Meemic Insurance Company, found that the Medicare reimbursement cap under MCL 500.3157(2) applies to those services.
The logic was straightforward: because Medicare pays for home health aide and skilled nursing care, the statutory cap kicks in. That means no-fault auto insurers are not required to pay more than what Medicare would pay for the same services. What the Court did not sort out, however, was how to actually calculate that Medicare amount in any given case – leaving a practical gap for insurers and providers.
That is where the bulletin comes in. DIFS Director Anita G. Fox laid out specific documentation requirements for providers looking to appeal reimbursement decisions through the Department's Utilization Review process. Providers must either supply the documented Medicare reimbursement rate for the services in question, or provide the data needed to run the calculation through the CMS Home Health PPS Web Pricer. That includes items such as the provider's CMS Certification Number, the patient's admission date, service date ranges, the beneficiary's geographic codes, and the patient-specific HIPPS code.
The Department made clear that its UR decisions will be based on whatever written materials the parties submit – and that gaps in documentation will not work in anyone's favor. Under Michigan Administrative Code R 500.65(4), if a party fails to supply information in a timely manner, the Department will simply decide based on what it has.
For providers who believe they are owed more money on claims affected by the ruling, the bulletin sets out a clear sequence: go to the insurer first and request reprocessing. If that does not resolve the dispute, the Department can step in. DIFS also pointed providers and insurers back to Bulletin 2025-11-INS, issued on April 25, 2025, which provides additional payment and billing guidance for the no-fault system.
The practical takeaway for Michigan's no-fault insurers is that home health aide and skilled nursing care claims now sit firmly within the Medicare cap framework – and that the Department expects both sides to come to the table with their numbers.
DIFS has indicated it will issue further guidance as needed.
