Massachusetts General Laws

Mass. Gen. Laws ch. 111, § 70A (2026)

Hospital lien; creation; priority; application

✓ current as of July 2026

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Section 70A. Any person and any city or town maintaining a hospital licensed under the provisions of section fifty-one, any hospital located in the commonwealth and operated by the United States Veterans Administration, any hospital operated by the commonwealth which furnished medical or other services to any person injured in an accident not covered by chapter 152 shall, subject to the provisions of section seventy B, have a lien for the reasonable and necessary charges of such hospital, not exceeding, however, the amount which would be charged in a ward of such hospital, and any health maintenance organization which has furnished health services, and any hospital, medical, or dental service corporation which has provided benefits for covered services furnished to a person injured in such an accident shall, subject to the provisions of section seventy B, have a lien for such benefits, upon the net amount payable to such injured person, his heirs or legal representative out of the total amount of any recovery or sum had or collected or to be collected, whether by judgment or by settlement or compromise, from another person as damages on account of such injuries. The lien of any attorney shall have precedence over the lien created under this section. The provisions of this section shall not apply to any such charges incurred subsequent to any such judgment, settlement or compromise.

Notes of Decisions

Cited in 10 cases (1 in the last 5 years), 1992–2025 · leading case: Golchin v. Liberty Mut. Ins., 950 N.E.2d 853 (Mass. 2011).

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Golchin v. Liberty Mut. Ins., 950 N.E.2d 853 (Mass. 2011). · cites it 2× “Specifically, Golchin’s demand letter and Liberty Mutual’s response letter both note that, pursuant to G. L. c. 111, § 70A, Blue Cross has filed a medical lien against Golchin’s recovery from the tortfeasor.”

Creswell v. Med. West Cmty. Health Plan, Inc., 644 N.E.2d 970 (Mass. 1995). · cites it 3× “727, 728-730 (1993), holding that benefits received from an under-insurance policy are not subject to a lien pursuant to G. L. c. 111, § 70A, because those benefits are contractual and not damages from third-party tortfeasors, is consistent with this restriction.”

Golchin v. Liberty Mut. Ins., 993 N.E.2d 684 (Mass. 2013). “Such expenses were clearly “incurred” within the plain language of the auto policy — first, by Blue Cross, and later by Golchin when the lien placed by Blue Cross on her tort recovery pursuant to G. L. c. 111, § 70A, 12 was satisfied. 13 Golchin therefore is entitled to recover…”

In Re Martinez-Whitford, 199 B.R. 74 (Bankr. D. Mass. 1996). “In the Meyers case, this distinction served as the basis of the court's conclusion that the proceeds of the insurance settlement were not subject to the statutory lien codified in Mass.Gen.L. ch. 111, § 70A (1990 ed.). 9 .”

Massachusetts Insurers Insolvency Fund v. Ladd, 658 N.E.2d 696 (Mass. App. Ct. 1995). “On November 28, 1988, North Shore notified all parties, including American Mutual, Sentry, and Ladd’s attorney, of its exercise of a lien pursuant to G. L. c. 111, § 70A, with reference to the benefits it had extended to Ladd.”

Ryan v. Somerville Hosp., 2 Mass. L. Rptr. 134 (Mass. Super. Ct. 1994). · cites it 7× “231 A, to declare the meaning of the words “reasonable and necessary charges” as used in G.L.c. 111, §70A. Additionally, plaintiff seeks a declaration that “where the work and skill of an injured party’s attorney results in a judgment or settlement whereby money is available for…”

Faria J. Simmons v. Nicole M. Chace (Mass. App. Ct. 2025). · cites it 2× “See Creswell, supra (PIP benefits are contractual obligations, not damages subject to G. L. c. 111, § 70A [statutory lien for damages provided to health maintenance organizations]); Meyers, 414 Mass.”

Creswell v. Med. West Cmty. Health Plan, Inc., 1 Mass. L. Rptr. 21 (Mass. Super. Ct. 1993). · cites it 4× “90, §34A from asserting any lien pursuant to the provisions of G.L. c. 111, §70A against the proceeds of a civil action brought by her against a third party alleging negligence in the operation of a motor vehicle.”

Blue Cross & Blue Shield of Massachusetts, Inc. v. Trull, 3 Mass. L. Rptr. 599 (Mass. Super. Ct. 1995). “In 1992, the plaintiff sought to impose a lien pursuant to G. L. c. 111, §70A on any recovery by the Trulls from a third party.”

Field v. Marino, 1992 Mass. App. Div. 180 (Mass. Dist. Ct., App. Div. 1992). “In Blue Cross (which was decided before legislation accorded statutory lien status to the type of claim made there, See G.L.c. 111, §70A, as amended by St. 1978, c.”

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