Tex. Codes » Labor Code · TITLE 5. WORKERS' COMPENSATION · SUBTITLE A. TEXAS WORKERS' COMPENSATION ACT · CHAPTER 409. COMPENSATION PROCEDURES
Texas Codes

Tex. Lab. Code § 409.009 (2026)

Subclaims

✓ current as of May 2026
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Sec. 409.009. SUBCLAIMS. A person may file a written claim with the division as a subclaimant if the person has:

(1) provided compensation, including health care provided by a health care insurer, directly or indirectly, to or for an employee or legal beneficiary; and

(2) sought and been refused reimbursement from the insurance carrier.

Acts 1993, 73rd Leg., ch. 269, Sec. 1, eff. Sept. 1, 1993.

Amended by:

Acts 2005, 79th Leg., Ch. 265 (H.B. 7), Sec. 3.140, eff. September 1, 2005.

Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 2001–2026 · leading case: Texas Mut. Ins. Co. v. Sonic Sys. Int'l, Inc., 214 S.W.3d 469 (Tex. App. 2007).
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Texas Mut. Ins. Co. v. Sonic Sys. Int'l, Inc., 214 S.W.3d 469 (Tex. App. 2007). · cites it 6× “TEX. LAB.CODE ANN. § 409.009 (Vernon 2006).”
Valley Forge Ins. Co. v. Austin, 65 S.W.3d 371 (Tex. App. 2001). · cites it 3× “Austin, has the right of a subclaimant, to pursue reimbursement from Valley Forge Insurance Company under Texas Labor Code § 409.009.” Furthermore, “[m]anifest injustice does not result from .”
Sonic Sys. Int'l, Inc. v. Croix, 278 S.W.3d 377 (Tex. App. 2009). “See Tex. Lab.Code Ann. § 409.009 (Vernon 2006) (providing generally that a person may file a subclaim with the TWCC if the person has provided compensation and sought and been refused reimbursement from the insurance carrier).”
In Re Texas Mut. Ins. Co., 331 S.W.3d 70 (Tex. App. 2011). “Tex. Lab.Code Ann. §§ 409.009, 409.011(b)(4) (Vernon 2006).”
Serv. Lloyds Ins. Co. v. Am. Alt. Ins. Corp., 306 S.W.3d 414 (Tex. App. 2010). · cites it 5× “Service Lloyds argues that a workers’ compensation carrier cannot be a subclaimant under Texas Labor Code section 409.009 and the Division had no jurisdiction to order such reimbursement.”
Valley Forge Ins. Co. v. Austin, 105 S.W.3d 609 (Tex. 2003). “To reach its decision, however, the court of appeals held that Texas Labor Code section 409.009 abrogated the doctrine in workers’ compensation cases where group health insurance is also involved.”
East Texas Educ. Ins. Ass'n v. Sanford Jones & James Thomas Lyle, as Indep. of the Est. of Mary Louise Jones, & Next Friend of J.L., a Minor (2026). · cites it 3× “” ETEIA argues that TRS- ActiveCare’s claim against ETEIA in the Orange County Lawsuit “was a subclaim pursuant to TEX. LABOR CODE § 409.009, for reimbursement of medical benefits.”
Serv. Lloyds Ins. Co. v. Am. Alt. Ins. Corp. (Tex. App. 2010). · cites it 5× “Service Lloyds argues that a workers' compensation carrier cannot be a subclaimant under Texas Labor Code section 409.009 and the Division had no jurisdiction to order such reimbursement.”
Serv. Lloyds Ins. Co. v. Am. Alt. Ins. Corp. (Tex. App. 2010). · cites it 5× “Service Lloyds argues that a workers’ compensation carrier cannot be a subclaimant under Texas Labor Code section 409.009 and the Division had no jurisdiction to order such reimbursement.”
Persimmon Ridge Partners EO, L.P., Russ Vandenburg, & Martha Vandenburg v. Fannie Mae (Tex. 2015). · cites it 2× “Workers' compensation carrier could be a subclaimant under Tex. Lab. Code Ann. § 409.009 , because a workers' compensation carrier was a person under Tex.”
Texas Workers' Comp. Comm'n v. Texas Worker's Comp. Ins. Fund, 132 S.W.3d 5 (Tex. App. 2003). “Under the “new law,” the Legislature created the right of a subclaimant for the first time, and, under Texas Labor Code section 409.009.... Any person or entity has an independent right as a subclaimant to seek reimbursement for any services for the workers’ compensation…”
Texas Workers' Comp. Comm'n v. Texas Workers' Comp. Ins. Fund (Tex. App. 2003). “Under the "new law," the Legislature created the right of a subclaimant for the first time, and, under Texas Labor Code section 409.009 . . . . Any person or entity has an independent right as a subclaimant to seek reimbursement for any services for the workers' compensation…”
Show all 18 citing cases →
— Tex. Lab. Code § 409.009(1) — 1 case
Serv. Lloyds Ins. Co. v. Am. Alt. Ins. Corp., 306 S.W.3d 414 (Tex. App. 2010). “Service Lloyds argues that a workers’ compensation carrier cannot be a subclaimant under Texas Labor Code section 409.009 and the Division had no jurisdiction to order such reimbursement.”
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