Colorado: Hotel and Restaurant Expenses for Out-of-Town Medical Treatment Need Not Be Advanced

Hotels and restaurants patronized by a workers’ compensation claimant during authorized travel out-of-town to obtain treatment by a specialist are not “medical providers” as that term is defined by § 8–42–101(4), C.R.S. (2012), held a Colorado appellate court recently. Accordingly, the carrier need not advance those particular costs associated with such travel in spite of the fact that it was required only to reimburse claimant after-the-fact. Using an “ordinary, everyday” meaning of the term “health care service,” the court indicated that it connoted only those services provided to “maintain or restore health.”

Reported by Thomas A. Robinson, J.D.

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See Winter v. Industrial Claim Appeals Office, 2013 COA 126, 2013 Colo. App. LEXIS 1284 (Aug. 15, 2013) [2013 Colo. App. LEXIS 1284 (Aug. 15, 2013)]

See generally Larson’s Workers’ Compensation Law, § 94.03 [94.03]

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law.

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