Michigan PIP Replacement Services: The $20-Per-Day Rule (2026)
A Michigan accident victim who cannot mow the lawn, do laundry, cook, or shovel snow because of injuries is entitled to recover the cost of someone else doing those chores. Under MCL 500.3107(1)(c), the no-fault carrier pays up to $20 per day, for up to three years from the date of the accident. The amount sounds small. Over three years, with proper documentation, it adds up to nearly $22,000 in tax-free benefits that most claimants never collect.
What the Statute Actually Says
MCL 500.3107(1)(c) provides PIP benefits for “expenses not exceeding $20.00 per day, reasonably incurred in obtaining ordinary and necessary services in lieu of those that, if [the injured person] had not been injured, [he or she] would have performed during the first 3 years after the date of the accident, not for income but for the benefit of [himself or herself] or of [his or her] dependent.” The benefit cap is statutory and has not been indexed for inflation since the original 1973 enactment. Every legislative session since 2019 PA 21 has left the $20 figure untouched.
Replacement Services vs. Allowable Expenses
The line between replacement services under subsection (1)(c) and allowable expenses under subsection (1)(a) is where most disputes live. Allowable expenses are unlimited in amount and payable for life when reasonable and necessary for the injured person’s care, recovery, or rehabilitation. Replacement services are capped, time-limited, and cover ordinary domestic chores. The same task can fall into either category depending on its purpose. Hiring a home health aide to dress a quadriplegic is allowable-expense attendant care; hiring a neighbor’s teenager to mow the lawn is replacement services. Coordinating these correctly is the single highest-yield drafting skill on a PIP claim.
| Service | Replacement Services (1)(c) | Allowable Expense (1)(a) |
|---|---|---|
| Lawn mowing, snow shoveling | Yes, $20/day cap | No |
| Bathing and dressing the claimant | No | Yes, unlimited |
| Laundry and cooking for family | Yes, $20/day cap | No |
| Medication management | No | Yes, unlimited |
| Childcare while parent is incapacitated | Yes, $20/day cap | No (unless medically necessary) |
| Transportation to medical appointments | No | Yes, unlimited |
The Three-Year Clock
The three-year period runs from the date of the accident, not the date of disability onset, surgery, or peak impairment. A claimant who needed no help for the first six months and then required extensive home support after a delayed-onset condition still has only two and a half years left on the clock. Counsel should calendar the three-year endpoint at intake and front-load documentation early.
The Family-Provider Question
Replacement services performed by a family member are compensable. The question is the reasonable hourly rate. Where a spouse or adult child performs services that would otherwise be hired out, courts look to comparable market rates for the same task. A teenager mowing the lawn is paid at teenager market rates. A retired parent doing daily laundry is paid at home-help rates. The carrier will routinely lowball by offering the federal minimum wage; counsel should document local going rates and contemporaneous newspaper or service-app advertisements for similar tasks.
Documentation That Wins These Claims
The single most common failure on replacement services claims is bad documentation. Claimants tell their lawyer that “my wife has been doing everything” without keeping daily logs. Reconstructing six months of chore hours after the fact is harder than it looks and gives the carrier ground for the “speculative” or “unreasonable” objection. The fix:
- Daily log book. A simple spiral notebook with date, task, hours, and who performed the task. One line per task. Sign each page.
- Comparable rate evidence. Save screenshots of TaskRabbit, Care.com, and local agency rates for the same task in the same ZIP code.
- Medical alignment. The treating physician’s restrictions should match the tasks listed. A restriction sheet that says “no lifting over 10 pounds” supports the laundry chore but not the heavy-snow-shovel chore.
- Receipts when paid. If a family member is paid by check, keep the checks. Cash payments require a contemporaneous ledger.
Submission Mechanics Under MCL 500.3142
PIP benefits are overdue if not paid within 30 days of the carrier’s receipt of reasonable proof of loss, per MCL 500.3142(2). Replacement services are no exception. A monthly submission cycle — daily log photocopies, family-provider invoices, and physician restriction sheets — both speeds payment and protects the one-year-back deadline under MCL 500.3145.
The One-Year-Back Rule and Replacement Services
MCL 500.3145(1) bars recovery of any benefit incurred more than one year before the date the action is filed. For replacement services, that means a claimant who delays a lawsuit for two years recovers at most one year of back chores. Our one-year-back rule guide walks through the tolling exceptions under Spine Specialists of Michigan v. MemberSelect Ins Co (Mich. Ct. App. 2024, published, affirmed by Mich. 2025) and Encompass Healthcare.
Attorney Fees on Replacement Services
Where the carrier unreasonably refuses or delays payment of replacement services, MCL 500.3148(1) shifts attorney fees to the carrier. The Pirgu v. United Services Auto Ass’n, 499 Mich. 269 (2016), eight-factor lodestar method governs the calculation. Carrier rejections of replacement services are often pro forma — a flat denial without any reasoning — which makes the unreasonable-refusal element easier to prove. See our no-fault attorney fees guide for the full Pirgu framework.
Carrier Defenses to Watch For
- “Would have been performed anyway.” Carriers argue that if a spouse always did the laundry, paying for it post-injury is not a covered expense. Michigan courts have consistently rejected that defense — the statute compensates the time the injured person can no longer contribute to the household.
- “Above market rate.” Carriers will pay the minimum and challenge anything above it. Counter with local rate evidence.
- “Beyond the medical restrictions.” If the treating physician has not endorsed an inability to perform the task, the carrier will deny. Update restriction sheets quarterly.
- “Cumulative log is unreliable.” Reconstructed-after-the-fact logs draw skepticism. Daily contemporaneous logs are harder to attack.
Coordination With Wage Loss and Attendant Care
Replacement services interact with wage loss under MCL 500.3107(1)(b) and family attendant care under our 56-hour cap guide. A spouse who quits a paying job to care for the injured claimant may recover wage replacement under (1)(b) for the lost income and replacement services under (1)(c) for the household chores the claimant can no longer do. Double-counting the same hour for both benefits is barred; clean log entries that distinguish “personal care” hours from “household chore” hours separate the two streams.
Frequently Asked Questions
How much can I recover per day in replacement services?
Up to $20 per day under MCL 500.3107(1)(c). The cap is statutory and has not been indexed for inflation.
For how long?
Three years from the date of the accident. There are no extensions.
Can my spouse be paid for doing my chores?
Yes. Replacement services performed by family members are compensable at the reasonable hourly rate for the task, measured by local market comparables.
What kinds of tasks count?
Ordinary and necessary household services the claimant performed before the accident for the benefit of the household — laundry, cooking, cleaning, yard work, snow removal, childcare, and similar chores.
What does not count?
Personal care services (bathing, dressing, medication management) — those are allowable expenses under MCL 500.3107(1)(a). Work that produces income is not covered either.
What if I forget to keep a daily log?
Reconstructed logs are sometimes accepted but invite carrier challenges. The cleaner the contemporaneous record, the higher the recovery. Start a log the day you read this article if you have not already.
What happens if the insurer refuses to pay?
MCL 500.3148(1) shifts attorney fees to the carrier when the refusal or delay is unreasonable. Most replacement-services denials are flat refusals without reasoning, which makes the fee-shift argument straightforward.
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