In Jawad A. Shah, M.D., P.C. v Auto Club Insurance Association, the Court held that insurers may apply Medicare's Multiple-Procedure Payment Reduction (“MPPR”) methodology when calculating payable PIP benefits under MCL 500.3157.

The dispute centered on whether the MPPR constituted a: “limitation[] unrelated to the rates in the fee schedule” under MCL 500.3157(15)(f).

Relying on Favot v Brown and Central Home Health Care Services v Progressive Michigan Insurance, the Court concluded the MPPR is sufficiently tied to Medicare reimbursement calculations because it directly affects: “the amount Medicare would pay for the particular service.”

As a result, insurers are permitted to incorporate MPPR reductions when determining the amount payable under Michigan's post-reform no-fault fee schedule.

Why this matters: This decision is another significant win for carriers litigating provider reimbursement disputes under the 2019 no-fault reforms. It reinforces that courts are increasingly interpreting “amount payable under Medicare” broadly enough to include Medicare reimbursement methodologies—not just raw fee schedule rates