July 21, 2026
One of the limits that Michigan’s no-fault insurance act places on an automobile insurer’s potential liability to pay for medical care is that an insurer is only required to pay “for reasonably necessary products, services and accommodations for an injured person’s care, recovery, or rehabilitation.” Thus, before an insurer can become liable the person seeking payment bears the burden of proving that the product, service, or accommodation was “reasonably necessary” for the “care, recovery, or rehabilitation” of a person injured in an automobile accident. This necessitates either: (a) proof that the product, service, or accommodation is generally accepted within the medical community; or, if not, then (b) objective and verifiable evidence that the product, service, or accommodation is efficacious (i.e., likely to be effective).
Ilham Elrahazoui allegedly suffered a back injury in an automobile accident. She sought treatment at SNM Physical Therapy, LLC, which sued Elrahazoui’s no-fault insurer seeking $140,300 in payment for Nervomatrix/Trigger Point Impedance Imaging (“TPII”) therapy. Nervomatrix TPII allegedly relieves back pain by using a proprietary algorithm to identify myofascial trigger points and then inject Electric Hyperstimulation Analgesia into those trigger points.
But, in the unpublished decision of SNM Physical Therapy, LLC v Citizens Ins Co of the Midwest, the Court of Appeals affirmed the Circuit Court’s dismissal of SNM Physical Therapy’s claim, holding that SNM Physical Therapy failed to proffer evidence that Nervomatrix TPII therapy was reasonably necessary for Elrahazoui’s care, recovery, or rehabilitation.
The Court of Appeals first determined that SNM Physical Therapy had effectively admitted that Nervomatrix TPII is not generally accepted in the medical community, noting that SNM Physical Therapy’s own medical expert described Nervomatrix TPII therapy as being “novel” and not among “conventional treatments,” and further stating that “additional research and larger clinical trials” were needed before Nervomatrix TPII could be “integrat[ed] into standard therapeutic protocols.”
The Court of Appeals then determined that SNM Physical Therapy had similarly failed to proffer objective and verifiable evidence that Nervomatrix TPII therapy is efficacious, noting that SNM Physical Therapy could not point to any independent, non-manufacturer-funded (i.e., objective) medical studies establishing that Nervomatrix TPII is likely to be effective and, in fact, that SNM Physical Therapy’s own medical expert had opined that further research and clinical trials were needed to “establish the device’s efficacy.”
As a result, the Court of Appeals affirmed the trial court’s granting of summary disposition in favor of Citizens.