Martin K. Eby Constr. Co. v. Industrial Comm'n
In Martin K. Eby Constr. Co. v. Industrial Comm'n, 710 P.2d 1164, 1166 (Colo. App. 1985), the Court of Appeals of Colorado has held that, where "a claimant has established that unauthorized medical treatment or vocational rehabilitation has reduced the degree of permanent partial disability from which the claimant would otherwise have suffered and that the expenses thus incurred are reasonably proportionate to the benefit received, the employer is liable for such unauthorized but reasonable expenses."
The court reasoned "that the employer may not disclaim responsibility for the expense of treatment from which it receives benefit." Id.