Appellate Court Rules No-Fault Policy Can't be Coordinated With Health Care Ministry Program

. . . If God had insurance, what would it be?
And would it coordinate benefits?
If it was faced with a Tousignant motion
How would the court rule?

 . . . And yeah, yeah, coor-din-ate
Yeah, yeah, do you think I could?
No, no, no-no-no

Recently, Joan Osborne... err ... the Michigan Court of Appeals issued a published decision concerning health care sharing ministries (i.e., a form of health care coverage) and their interplay with the Michigan No-Fault Act’s coordination of coverage.

In Meemic Insurance Co v Christian Care Ministry, Inc, the insured was injured in a motor vehicle accident. At that time, he was a participant in a health care sharing ministry and had a coordinated policy of no-fault insurance. The insurance company argued that MCL 500.3109a obligated the health care sharing ministry to be the primary payer as it would qualify as “other health and accident coverage.” The trial court disagreed, and this appeal followed.

When reviewing the plans, the appellate court noted that a health care sharing ministry program is not traditional health insurance. Rather, it is faith-based arrangement that provides for the financial or medical needs of a participant through voluntary donations. The appellate court remarked that many different types of benefit programs fit within the confines of the “other health and accident coverage” provision of MCL 500.3109a. But, ultimately, it felt that coordinating benefits with a health care sharing ministry was “a bridge too far.”

In reviewing the finer points of the health care sharing ministry program, the appellate court did not believe that it qualified as “other health and accident coverage” because: (1) it is not the type of coverage that is typically provided by an insurance company as it relies solely on the generosity of others; (2) the statute pertaining to health care sharing ministry programs mandates that its participants remain personally liable for the medical bills despite any assistance received; and (3) a health care sharing ministry program is not akin to self-insurance as no participant indemnifies himself or herself to satisfy medical expenses.

As a result, the appellate court did not believe that a health care sharing ministry program was within the contemplation of the No-Fault Act for purposes of coordination and affirmed the decision of the trial court.

So, what is the practical effect of this decision? Frankly, it is not likely to come up too often. The reality is that participation in health care ministry programs is not common. According to the Alliance of Health Care Sharing Ministries, the State of Michigan had 22,173 members in 2020, which equated to about 0.2% of Michigan’s population. While this published decision should be noted, the odds that a No-Fault insured will be a participant in a health care sharing ministry program is rather small.

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