PIP benefits are "payable" as loss "accrues" and "benefits payable ‘accrue not when the injury occurs but as the allowable expense, work loss or survivor's loss is incurred.’ " Id. (citing Mich. Comp. Laws §§ 500.3142, 500.3110(4) ); see alsoNorth Shore Injury Ctr., Inc. v. Home-Owners Ins. Co. , No. 340357, 2019 WL 939031, at *3 (Mich. App. Feb. 26, 2019) ("Because each payments presents a new claim, the no-fault act necessarily permits multiple suits to enforce the payments."). In Shures , 2009 WL 3052239, at *3, the Court explained that, although the prior action was decided on the merits and both actions involved the same parties, because the plaintiff could not have brought a claim for benefits, which had yet to accrue, in the prior action, the present action could not have been "resolved in the first [action]" and the plaintiff's claim was not barred by res judicata.

Because MCL 500.3142 requires prompt payment of no-fault PIP benefits as they accrue, Michigan courts have permitted partial assignments to individual providers to ensure this prompt payment. Id. at 723; North Shore Injury Center Inc. v. Home-Owners Ins. Co., No. 340357, 2019 WL 939031, at *3 (Mich. App. Feb. 26, 2019) ("Because each payment presents a new claim, the no-fault act necessarily permits multiple suits to enforce the payments."); see also MCL 500.3142 (stating that No-Fault PIP benefits "are overdue if not paid within 30 days after an insurer receives reasonable proof of the fact and of the amount of loss sustained). "Furthermore, MCL 500.3112 contemplates that an insurer may discharge its obligation to the insured with respect to particular benefits that have been incurred by directing payment of those benefits to the party providing services to the injured party.