Colorado Reaches $30,000 Settlement With Wakefield Over Medical Debt Collection Practices

Case Snapshot

• Court/Agency: Colorado Attorney General’s Office
• Case: State enforcement action involving Wakefield & Associates
• Announcement Date: Sept. 23, 2026
• Core Issue: Compliance with Colorado’s medical debt collection and default judgment documentation requirements
• Key Allegation: The state alleged Wakefield sought default judgments without submitting evidence required under SB 23-093.
• Holding: No adjudicated finding of liability. The matter was resolved through a stipulated settlement, and Wakefield denied wrongdoing.
• Outcome: $30,000 fine, vacation of certain unsatisfied default judgments involving 44 accounts, potential consumer refunds, and prospective compliance requirements
• Notable Detail: Weiser described the matter as the state’s first enforcement action under the 2023 medical debt protections

Colorado has reached a settlement with Wakefield & Associates over alleged violations of the state’s medical debt collection requirements, marking what Attorney General Phil Weiser described as the first enforcement action under a 2023 law that imposed new documentation requirements on medical debt lawsuits.

Under the settlement, Wakefield agreed to pay a $30,000 fine, vacate certain unsatisfied default judgments involving 44 Colorado accounts and potentially refund payments made by some consumers after judgments were entered, according to reporting by Denver7 Investigates. Wakefield denied wrongdoing and maintained that its collection activities complied with Colorado law.

The action puts medical debt collectors operating in Colorado on notice about the state’s expectations for documentation submitted in collection litigation, particularly when seeking default judgments.

State Alleges Required Evidence Was Missing

The Colorado Attorney General’s Office alleged that Wakefield sought default judgments without submitting evidence required by Senate Bill 23-093, which became law in 2023.

According to Denver7, state regulators determined that Wakefield sometimes relied on assignment documents that were insufficient to establish the medical debts under Colorado law. Wakefield disputed the state’s position in the settlement and did not admit that its practices violated state law.

The settlement requires Wakefield to vacate certain unsatisfied default judgments associated with 44 identified accounts. The company cannot pursue new judgments on those accounts unless consumers receive new notice and compliant affidavits are filed. Some consumers who made payments after judgments were entered also could qualify for refunds.

Weiser told Denver7 that his office is concerned other collectors may also be failing to comply with the law.

Colorado Law Sets Evidence Requirements for Medical Debt Lawsuits

Senate Bill 23-093, signed into law May 4, 2023, established several protections governing medical debt collection. Among other provisions, it capped interest on medical debt at 3% annually, established requirements for payment plans, and restricted collection activity while certain health insurance appeals are pending.

The law also directly addresses collection litigation. A creditor, debt collector, or collection agency filing an action to collect medical debt must attach a redacted itemization of the charges forming the basis of the debt.

Before a court enters a default judgment, the plaintiff must submit evidence establishing the amount and nature of the debt. The required information includes the original account number and creditor at charge-off, the amount due at charge-off or an itemization of the amount claimed, post-charge-off additions, the date of the last payment or transaction, and the date the debt was incurred. Those requirements appear in Section 5 of the signed act, on pages 5 and 6.

The law further states that an affidavit lacking the evidence required by those provisions does not satisfy the statutory requirements.

SB 23-093 also requires collectors, upon a consumer’s written request, to cease collecting medical debt until they can provide an itemized statement containing specified information about the creditor, services, principal balance, payments, credits, and other components of the account.

Settlement Highlights Litigation Compliance Risk

For accounts receivable management companies handling Colorado medical debt, the settlement provides a concrete example of how the state may enforce SB 23-093.

The action particularly highlights the documentation required before seeking a default judgment. Agencies and creditors pursuing medical debt litigation in Colorado may need to review whether account records, affidavits, and supporting documentation contain each element required under state law before requesting judgment.

The settlement also demonstrates that potential remediation can extend beyond prospective compliance. Wakefield agreed to vacate certain existing judgments, and payments made following some judgments could be subject to refunds.