Grover Medical Benefits

An important appellate case, Grover v Industrial Comm’n, 759 P.2d 705 (Colo. 1988), stands for the proposition that the claimant may receive medical benefits that are reasonable, necessary, related and provided by authorized treating physicians to alleviate the effects of the industrial injury long after the claimant reaches maximum medical improvement (MMI).  Some interpret this case to mean that medical benefits may be provided for as long as those benefits are reasonably necessary, perhaps for a lifetime.  (See Section 8-42-101(1) (a), C.R.S.).  Carriers are required to take a position on post-MMI medical benefits when completing a Final Admission of Liability.  Because medical benefits can remain open long after all indemnity benefits are paid out, a carrier often seeks to negotiate a  “full and final settlement”.  Such a settlement would  close out a claimant’s right to future medical benefits and would allow the carrier to close their file forever.