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Colorado Auto Insurance & Crash Law · Citizen Guide 21

MedPay, Medical Bills, Liens & Subrogation

After a serious crash, one medical service can produce several different legal and financial records: a provider bill, a MedPay claim, a health-insurance payment, an adjustment, an unpaid balance, a lien, a Medicaid or Medicare recovery interest, or a contractual reimbursement demand. The first task is classification. Do not pay a label. Identify the legal basis, amount, priority and proof behind each claimed obligation.

Guide 21 of 23 Current-law review: Sept. 13, 2026 § 10-4-635 · Colorado MedPay Bills ≠ Liens ≠ Reimbursement

Start by separating the payment systems

Medical treatment may be one event. Payment is not one system. Each payer or claimant can operate under different statutes, contracts, deadlines and recovery rights.

1 · MedPayFirst-party automobile coverage. Track limit, eligible claimant, submitted bills, payments, denials, trauma reserve and exhaustion.
2 · Health BenefitsHealth insurer, HMO, employer plan, Medicare or Medicaid. Track EOBs, adjustments, member responsibility and recovery rights.
3 · Provider AccountWhat the hospital or provider billed, adjusted, accepted, wrote off, assigned, placed with collections or claims remains due.
4 · Recovery ClaimHospital lien, provider lien, Medicaid lien, Medicare recovery or contractual reimbursement claim against settlement proceeds.
The account balance is not automatically the settlement lien. A bill tells you what a provider says is owed. A lien or reimbursement claim requires its own legal basis, perfection, amount and priority analysis.

Colorado MedPay begins with a statutory $5,000 offer

Under C.R.S. § 10-4-635, a Colorado automobile liability policy within the statute generally must provide medical-payments coverage of at least $5,000 unless the named insured rejects the coverage in the required manner.

Default

$5,000 MedPay

The statute requires the coverage to be provided in the policy or supplemental policy unless an applicable exception or valid rejection exists.

Rejection

Document it

The named insured may reject MedPay in writing or in the same medium in which the application was taken. The insurer must maintain rejection proof for at least three years.

Missing proof

Presumed $5,000

If the insurer fails to offer MedPay or fails to maintain or provide the required rejection proof, the policy is presumed to include $5,000 in MedPay.

Coverage class

Read the policy and statute

The statutory definition includes the insured and an authorized passenger in the insured vehicle who sustains bodily injury arising from its use. Policy wording and statutory exceptions still matter.

MedPay does not depend on proving the other driver was negligent. It is a first-party medical-payments benefit. Liability, comparative fault and a third-party bodily-injury settlement are separate tracks.

The first $5,000 can be subject to a 30-day trauma reserve

Colorado gives specified trauma providers a temporary payment priority after notice of a crash.

Colorado MedPay trauma reserve priorities.
PriorityProviderWhat to track
1Licensed ambulance or air ambulance providing qualifying trauma care at or immediately after the crashDate of service, transport, amount submitted, receipt date and payment.
2Qualifying trauma physicians providing stabilization or the first episode of careSeparate physician group bills from facility bills.
3Level IV or V trauma center providing qualifying trauma careConfirm facility designation and claim timing.
4Level I, II or III trauma center or regional pediatric trauma centerTrack what remains after higher statutory priorities.
The reserve is temporary. Section 10-4-635 generally requires the $5,000 reserve to be held for no more than 30 days after receipt of crash notice. After that period, unclaimed reserve funds may be available for other qualifying providers.

MedPay has a statutory claim-handling clock

C.R.S. § 10-4-642 defines a “clean claim” and requires insurers to maintain documentation sufficient to reconstruct material claim activity.

Forms

15 calendar days

Upon request, the insurer must provide its claim-filing requirements within 15 calendar days. After specified claim/loss notices, necessary forms and instructions also have a 15-day statutory framework.

Electronic clean claim

30 calendar days

A clean claim submitted electronically generally must be paid, denied or settled within 30 calendar days after receipt.

Other clean claim

45 calendar days

A clean claim submitted by another permitted method generally carries a 45-calendar-day period after receipt.

Build a MedPay claim log. For every bill record service date, provider, amount, date submitted, delivery proof, insurer receipt date, claim number, payment, denial reason, remaining benefit and exhaustion date.

Health insurance and MedPay can both matter

Do not assume that paying a bill through one source closes every other account or recovery issue.

Comparison of Colorado MedPay and health-benefit payment tracks.
QuestionMedPayHealth benefit plan
SourceAutomobile policyHealth policy, HMO, employer plan, Medicare, Medicaid or other plan
Fault required?Generally no third-party fault showing to access first-party benefitUsually no tort-fault determination required for ordinary covered care
LimitPolicy limit; statutory offer starts at $5,000 unless validly rejectedPlan-specific deductibles, copays, network rules and benefit limits
Recovery interest?Colorado statute sharply restricts ordinary MedPay recovery against tortfeasorsMay involve contractual, statutory or federal reimbursement/subrogation rules
Key recordsDeclarations, rejection, policy, payment ledger, exhaustion letterEOBs, plan document, SPD, payment ledger, reimbursement correspondence

Colorado generally protects full compensation before ordinary health-plan reimbursement

C.R.S. § 10-1-135 expresses Colorado's made-whole policy for covered “payers of benefits.” In general, contractual reimbursement or subrogation is permitted only after the injured person has first been fully compensated for all damages arising from the claim, and any permitted recovery is subject to statutory limitations and a proportionate attorney-fee/expense reduction.

Do not apply § 10-1-135 to every repayment demand. The statute expressly excludes Colorado Medicaid and the Children's Basic Health Plan from its definition of “payer of benefits,” preserves hospital liens and workers' compensation rights, and federal law can alter the analysis for Medicare and some ERISA plans.
Question 1

Who is demanding repayment?

Commercial health insurer, fully insured employer plan, self-funded ERISA plan, Medicaid, Medicare, workers' compensation, hospital or provider?

Question 2

What is the legal source?

Policy language, plan document, state statute, federal statute, assignment, lien agreement or court order?

Question 3

What was actually paid?

Separate billed charges, contractual write-offs, actual payments, member payments and claimed recovery amount.

Question 4

What reductions apply?

Made-whole rules, common-fund/attorney-fee reductions, statutory compromise procedures, allocation or federal rules may matter.

A Colorado hospital lien has statutory prerequisites

Article 27 of title 38 does not authorize a hospital simply to bypass identified insurance and attach full chargemaster rates to the settlement without following the statute.

Identify available payers. Before creation of a lien, § 38-27-101 generally requires the hospital to submit reasonable and necessary charges to identified available property/casualty and primary medical payers in the manner required by the statute.
Check whether the lien was properly created. If no payer is identified because the patient lacks insurance, a lien may be created. If a payer is later identified, the hospital must make good-faith efforts to submit the charges to that payer.
Check filing and notice. Section 38-27-102 provides for filing with the Colorado Secretary of State before judgment, settlement or compromise and specified certified-mail notice within ten days after filing.
Check the amount. The statutory lien is for reasonable and necessary hospital charges and is against the net recovery, subject to article 27.
Check enforcement and settlement risk. A settling party who pays over proceeds despite proper lien notice can face statutory exposure under § 38-27-103.
Colorado provides a remedy for a prohibited hospital lien. Section 38-27-101(7) permits an injured person subject to a lien in violation of that section to bring a district-court action to recover two times the amount of the lien attempted to be asserted.

Nonhospital health-care provider liens are a separate statutory system

Colorado article 27.5 regulates liens created by health-care providers or assignees against third-party or UM/UIM recoveries. It is separate from the hospital-lien article.

Disclosure

Before the lien

Section 38-27.5-104 requires specified disclosures and advisements before creation of a health-care provider lien, including potential payment alternatives.

Amount

No inflated add-ons

Section 38-27.5-105 limits the lien to the provider's usual and customary billed charge and prohibits finance charges or other increases prohibited by the statute.

Assignment

Assignee takes restrictions too

An assignee takes the lien subject to article 27.5's restrictions. The amount paid for the assignment and specified assignment information receive special evidentiary treatment under § 38-27.5-103.

Do not call every letter of protection a statutory lien. Determine whether the provider is claiming a statutory article 27.5 lien, a contractual payment agreement, an assignment, a collection balance or some other obligation.

Hospital Discounted Care can change what the patient is legally billed

Colorado's Hospital Discounted Care system is a patient financial-assistance framework. It is not automobile insurance and should not be confused with MedPay.

Screening

Uninsured patients—and insured patients on request

Section 25.5-3-502 requires screening of uninsured patients unless declined and allows an insured patient to request screening.

2026 update

Uniform application

Effective August 12, 2026, § 25.5-3-502.5 establishes a uniform discounted-care application process when additional information is required or the patient requests an application.

Discount

Qualified-patient rate

Section 25.5-3-503 limits qualifying charges to the discounted rate established by HCPF rules and imposes statutory installment-payment limits.

Payment plan

36-month endpoint

For qualifying charges under § 25.5-3-503, after a cumulative 36 months of required payments the remaining balance is treated as paid in full and collection activity must cease.

A serious crash can involve both MedPay and Hospital Discounted Care. Analyze them independently. One answers an auto-policy benefit question; the other answers a hospital/professional billing and financial-assistance question.

Medicaid and Medicare require their own recovery tracks

Colorado Medicaid

Statutory lien

C.R.S. § 25.5-4-301 gives HCPF specified recovery and lien rights when medical assistance was furnished and a third party is liable. The statute also contains notice duties when a member or representative asserts a third-party claim.

Medicare

Federal secondary-payer system

Medicare conditional-payment and recovery rights arise under federal law. Obtain the recovery information and resolve the federal interest rather than treating Medicare like an ordinary commercial health insurer.

Do not settle around a known public-benefit recovery interest. The claimant, attorney, insurer and settling parties can face statutory consequences depending on the program. Obtain the current demand or recovery information and use the applicable compromise/appeal process where available.

Employer health plans require plan-level classification

“ERISA” is not one reimbursement rule. Determine whether the plan is fully insured or self-funded, obtain the governing plan document and summary plan description, identify reimbursement language, and analyze federal preemption before assuming Colorado's § 10-1-135 controls.

Ask for the actual plan—not merely a recovery vendor's letter. A vendor demand should identify the plan, authority to act, amount paid for crash-related care, contractual provisions relied upon and calculation of the claimed reimbursement.

Build one medical-payment ledger

The ledger should let another reviewer reconstruct where every medical dollar went.

Provider / item
Billed
Paid
Balance
Claimed recovery
Ambulance
$___
MedPay $___
$___
None / verify
Hospital facility
$___
Health $___
$___
Hospital lien? $___
ER physician
$___
$___
$___
Provider lien? $___
Health plan
$___ benefits
Reimbursement $___
Medicaid / Medicare
$___
Recovery $___
  • Provider name and account number
  • Date(s) of service
  • Original billed amount
  • Contractual adjustment / write-off
  • Health insurer payment
  • MedPay payment
  • Patient payment
  • Current balance
  • Collections status
  • Lien type and recording information
  • Reimbursement claimant
  • Amount actually paid by claimant
  • Reduction / compromise requested
  • Final resolved amount

Gross settlement is not net recovery

Before signing a release, create a settlement distribution statement that separates confirmed obligations from disputed or unverified demands.

Pre-settlement medical obligation audit.
ClaimVerifyDo not assume
MedPayLimit, payments, denials, exhaustion and whether any benefit remainsThat MedPay is a lien against the settlement
Hospital lienStatutory prerequisites, payer submission, filing, notice and amountThat the gross hospital balance equals a valid lien
Provider lienArticle 27.5 disclosure, amount and agreementThat every provider balance has settlement priority
Commercial health planPlan type, payment ledger, reimbursement provision and § 10-1-135 analysisThat the recovery vendor's opening demand is final
MedicaidHCPF lien/recovery amount, notice and statutory reduction procedureThat ordinary made-whole law controls
MedicareConditional-payment record and final demand processThat an EOB or provider balance resolves Medicare's federal interest
ERISA planActual plan documents, self-funded status, language and federal lawThat state reimbursement limits necessarily apply
No release before the medical-money map is mature. A liability settlement can look adequate in gross dollars and still produce a poor net result if liens, reimbursement interests, unpaid bills and UM/UIM rights are unknown.

Citizen workflow: from first bill to final distribution

Obtain the complete auto policy. Confirm MedPay coverage, limit, claimant status, exclusions and any rejection document.
Open the MedPay ledger. Record every bill submitted, proof of delivery, payment, denial and remaining benefit.
Track the trauma reserve. Identify whether the statutory 30-day reserve affected early payments and when the reserve expired.
Send bills through available health coverage. Preserve EOBs, network adjustments and balances. Do not assume a crash means ordinary health insurance should be bypassed.
Request Hospital Discounted Care screening when relevant. An insured patient may request screening; preserve the screening/application result and payment-plan calculation.
Identify every asserted lien. Classify hospital liens separately from article 27.5 provider liens and contractual payment agreements.
Identify reimbursement claimants. Commercial plans, ERISA plans, Medicaid, Medicare and workers' compensation do not all use the same rule.
Demand itemization and authority. Obtain the payment ledger, plan/statutory basis, claimed amount and calculation for each repayment demand.
Challenge invalid or excessive claims. Use the governing statute, plan language, made-whole/common-fund rules, appeal rights and compromise procedures that actually apply.
Build the settlement distribution worksheet. Gross recovery minus verified fees, costs, valid liens, agreed reimbursement and unpaid obligations equals estimated net recovery.
Preserve UM/UIM and unresolved first-party rights. Do not let the medical-payment analysis disappear inside a broad third-party release.
Close with proof. Obtain final lien releases, zero-balance or satisfaction letters, reimbursement resolution, settlement disbursement record and MedPay exhaustion confirmation.

Primary authority map

Colorado statuteC.R.S. § 10-4-635 — Medical payments coverage

Mandatory $5,000 offer, rejection/proof rules, trauma reserve, ordinary anti-recovery rule and definitions.

Official 2026 Colorado Title 10 →
Colorado statuteC.R.S. § 10-4-642 — Prompt payment of direct benefits

Clean-claim definition, submission methods, documentation requirements and prompt-payment periods for MedPay claims.

Official 2026 Colorado Title 10 →
Colorado statuteC.R.S. § 10-1-135 — Reimbursement for benefits

Colorado's full-compensation / made-whole framework, reimbursement limits, fee sharing, notices and exclusions.

Official 2026 Colorado Title 10 →
Colorado statutesC.R.S. §§ 38-27-101 to -106 — Hospital liens

Available-payer submission, lien creation, filing/notice, enforcement and related hospital-lien rules.

Official 2026 Colorado Title 38 →
Colorado statutesC.R.S. §§ 38-27.5-101 to -108 — Health-care provider liens

Separate nonhospital provider-lien system governing disclosures, assignment, amount, disputes and priority.

Official 2026 Colorado Title 38 →
Colorado statutes · 2026 updateC.R.S. §§ 25.5-3-502 to -506 — Hospital Discounted Care

Screening, uniform application, discounted rates, payment plans, notice and collection protections. Updated in 2026 by SB 26-138.

Official 2026 Colorado Title 25.5 →
Colorado MedicaidC.R.S. § 25.5-4-301 — Medicaid recovery and liens

HCPF third-party recovery, automatic statutory lien, notice and related procedures.

Official 2026 Colorado Title 25.5 →
Federal42 U.S.C. § 1395y(b) — Medicare Secondary Payer

Federal framework for Medicare conditional payments and recovery where another payer is primary.

Federal statute →
FederalERISA · 29 U.S.C. § 1001 et seq.

Federal employee-benefit law that can affect reimbursement rights and state-law preemption for employer health plans.

ERISA statutory chapter →

Frequently asked questions

Is MedPay required in Colorado?

Colorado generally requires an automobile policy within C.R.S. § 10-4-635 to provide at least $5,000 in MedPay unless the named insured validly rejects it or a statutory exception applies.

What if the insurer cannot produce my MedPay rejection?

If the insurer failed to offer MedPay or fails to maintain or provide the rejection proof required by § 10-4-635, the statute provides a presumption that the policy includes $5,000 in MedPay.

Does MedPay have to be repaid from my liability settlement?

Do not assume so. Section 10-4-635(3) bars the MedPay insurer from ordinary recovery against the tortfeasor for MedPay benefits paid and bars a direct tortfeasor action. Other payment systems—health plans, Medicaid, Medicare, workers' compensation, hospital/provider liens—have different rules.

Why did the insurer hold some MedPay instead of paying my later provider?

After notice of a qualifying crash, Colorado law can require the insurer to reserve $5,000 for specified trauma providers for up to 30 days. That temporary priority can affect payment timing.

Does a hospital automatically have a lien because I was injured by another driver?

No. Colorado's hospital-lien statute contains payer-submission, filing, notice and other prerequisites. Obtain the lien documents and test statutory compliance rather than relying on the word “lien” on a bill or letter.

Can an insured patient request Hospital Discounted Care screening?

Yes. Current § 25.5-3-502 allows an insured patient to request screening. Eligibility and the resulting discount/payment plan depend on the statutory and regulatory criteria.

Does Colorado's made-whole law eliminate every reimbursement claim?

No. Section 10-1-135 is powerful but not universal. It contains exclusions and does not displace Medicaid, hospital-lien or workers' compensation rights; federal Medicare and ERISA issues may require separate analysis.

What should I know before settlement?

Know the MedPay status, every provider balance, every asserted lien, every health-plan/public-benefit recovery interest, the amount and legal basis of each claim, available reductions, UM/UIM posture and the estimated net recovery after verified obligations.

Do not ask only, “How much are the medical bills?”

Ask who billed it, who paid it, what was adjusted, what remains due, whether a valid lien exists, whether a payer has a lawful reimbursement right, what reductions apply, and what the injured person will actually receive after settlement. One coordinated ledger turns a fragmented billing system into a reviewable claim file.

Public legal education only. VictimsGuide.com does not provide individualized legal advice and does not create an attorney-client relationship. Medical-payment disputes can involve policy language, state insurance law, hospital/provider lien statutes, Hospital Discounted Care, Medicaid, Medicare, ERISA, workers' compensation, bankruptcy, probate, collection law and settlement terms. Verify the current governing authority, plan documents, lien records, balances and deadlines before legal reliance or distribution of settlement proceeds.