Worksheet · Personal Injury · Insurance Coverage

Coverage-Inventory Worksheet: Finding Every Policy After a Serious Injury

Serious-injury coverage analysis starts by identifying every potentially applicable policy and insured, then reading the actual declarations, endorsements, exclusions, notice provisions, and settlement-consent terms before any release is signed.

By Lincoln Square Law · 9-minute read

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After a catastrophic injury, the money that will pay for a lifetime of care is scattered across policies nobody has gathered in one place: the at-fault driver’s, the vehicle owner’s, an employer’s, your own, a relative’s in your household, and umbrellas sitting quietly on top of all of them. This worksheet is the tool for finding every layer before a single release is signed, because releasing one carrier too early can forfeit access to another. It pairs with the deeper “policy-limit archaeology” approach. Here you do the digging, line by line.

Layer 1: the at-fault party

• The at-fault driver’s liability policy: insurer, policy limits, and adjuster.
• If they were driving someone else’s vehicle: the vehicle owner’s policy (often primary).

Layer 2: employers and third parties

• Product liability: a defective vehicle, tire, or part maker (their coverage is often substantial).
• Commercial/government defendant: note any shortened notice deadlines that apply.

Layer 3: your own and household coverage

• Your umbrella policy, which may include excess UM/UIM.
• Med-pay / PIP on any applicable policy for immediate medical costs.

Start with people, vehicles, entities, and relationships

A coverage inventory should begin with the accident facts, not an insurer list. Identify every person and entity whose conduct may matter, who owned or controlled the vehicle or premises, whether anyone was working, whether a vehicle was borrowed, rented, leased, or company-owned, and whether the injured person lived with relatives who maintained auto policies. Each relationship can point to a different policy or insured status.

Do not assume that the policy carried by the person who caused the crash is the only relevant contract. A business owner, employer, vehicle owner, household policyholder, umbrella carrier, rideshare company, premises owner, contractor, or product manufacturer may have separate coverage. The worksheet is a discovery tool: it records what might exist so counsel can obtain and interpret the actual policy language.

Build a declarations-page file before debating coverage

For every identified policy, request or preserve the declarations page and all endorsements that change limits, named insureds, covered autos, exclusions, deductibles, self-insured retentions, or UM/UIM terms. Record policy number, effective dates, named insured, vehicle or risk, per-person and per-occurrence limits, umbrella or excess status, and the adjuster contact. A claim-system screen or verbal statement of limits is not a substitute for the policy materials needed to analyze coverage.

If a carrier says no coverage exists, capture the exact reason and request the written position. If the issue involves a reservation of rights or coverage litigation, treat it as a separate legal track from the liability case. The inventory should show what is known, what is disputed, and what documents are still missing.

Separate liability coverage from UM and UIM coverage

Illinois requires uninsured motorist coverage in motor-vehicle liability policies subject to 215 ILCS 5/143a, and Section 143a-2 governs additional UM/UIM coverage and the relationship to bodily-injury limits unless coverage is rejected as the statute permits. Those statutes establish important coverage architecture, but the applicable amount and insured status still depend on the specific policy, endorsements, vehicles, and facts.

List the injured person’s own auto policy and policies issued to resident household members. Identify whether the claim involves an uninsured vehicle, hit-and-run facts, or an at-fault liability limit that may be lower than applicable UIM coverage. Do not assume a household policy applies or does not apply without reading its definitions and exclusions. Record each potential policy separately.

Look for commercial, employer, and umbrella layers

If the person who caused the injury was working, identify the employer, the work purpose, the vehicle owner, and any commercial auto, general-liability, umbrella, or excess coverage. If a business owned the premises or equipment, identify the entity and any property-management, contractor, or vendor relationships. Commercial layers can have different notice requirements, deductibles, retentions, additional insured provisions, and coverage defenses than a personal auto policy.

For each excess or umbrella policy, record the attachment point and the underlying policies it requires. An umbrella is not simply “more insurance”. It may follow form, contain independent exclusions, or require exhaustion of specified underlying limits. The inventory should show the sequence in which layers may respond rather than adding limits together without analysis.

Record policy conditions before any settlement or release

A liability settlement can interact with UM/UIM consent, subrogation, exhaustion, notice, and proof requirements. The exact requirements come from the policy and governing law. Before signing a release, accepting limits, dismissing a defendant, or agreeing to confidentiality that affects another carrier, identify whether another policy requires notice or consent. Escalate the issue before the transaction becomes irreversible.

Use a “conditions” column for each policy: prompt notice, recorded statement, medical authorization, examination under oath, independent medical examination, proof of claim, suit limitation, arbitration, consent to settlement, cooperation, subrogation, and notice of other insurance. The worksheet does not decide whether a condition is enforceable. It ensures the condition is not overlooked.

Track health, disability, workers’ compensation, and benefit-plan intersections

A serious injury may involve medical payments coverage, health insurance, Medicare or Medicaid, disability benefits, workers’ compensation, ERISA plan reimbursement, or provider liens in addition to liability coverage. Those programs are not interchangeable with liability insurance. Record who paid what, any reimbursement or subrogation notice, and the contact for each payer. Keep the coverage inventory focused on sources and obligations rather than treating every payment as part of a single settlement fund.

If the injury occurred in the course of employment, separate the workers’ compensation claim and any third-party liability claim. Counsel can then evaluate lien, credit, and reimbursement consequences under the law applicable to the particular benefits. The worksheet should flag the intersection instead of assuming one claim eliminates the other.

Use minimum-liability law as a floor, not a policy-limit assumption

Illinois Motor Vehicle Safety Responsibility Law sets minimum liability amounts, but statutory minimums do not tell you the actual limits on a given policy. A policy may carry higher limits, commercial coverage, umbrella coverage, or self-insurance. Conversely, a vehicle or defendant may present coverage exclusions or defenses that require analysis. Record statutory minimums only as context. Obtain the policy evidence needed to determine actual available coverage.

The same discipline applies to verbal “policy limits” representations. Note who provided the information, when, and in what form. Ask whether the figure is per person, per occurrence, combined single limit, aggregate, reduced by prior claims, or subject to defense costs. Precise labels prevent false certainty.

Finish with a coverage map and unresolved-issue list

The final inventory should show each potential policy as a row and each open issue as a separate flag: policy missing, named-insured status unclear, household residency disputed, business-use exclusion asserted, umbrella not produced, UM/UIM consent pending, or other insurance unidentified. Assign each missing item to an owner and date. Coverage work is iterative. New facts from discovery can add or remove layers.

Do not let the worksheet become a release checklist that assumes a settlement should occur. Its purpose is to prevent an early release from being signed before counsel understands the available layers, conditions, liens, and subrogation consequences. Preserve the final coverage map with the claim file and update it whenever a new policy or coverage position appears.

Revisit the map when discovery changes the facts

Coverage analysis changes when new facts appear. A deposition may reveal a business purpose, a lease may identify an additional insured, a police report may name a vehicle owner, or written discovery may disclose an umbrella carrier. Set a recurring review point after major discovery events and update the map instead of treating the first inventory as final.

Keep a version history showing what policy was added, removed, or reclassified and why. That history helps counsel explain settlement strategy and avoids the risk that an early assumption quietly controls the case after the evidence changes.

Map every party, policy, coverage layer, condition, and lien

• Identify every potentially responsible person, vehicle owner, employer, business, property owner, and contractor.
• Obtain declarations pages, endorsements, effective dates, named insureds, and limits for each policy.
• List personal and household UM/UIM policies separately and flag residency or insured-status questions.
• Identify commercial auto, general liability, umbrella, excess, and self-insured layers.
• Record notice, consent-to-settle, cooperation, arbitration, suit-limitation, and subrogation conditions.
• Track health-plan, workers’ compensation, disability, Medicare/Medicaid, and lien intersections separately.
• Do not sign a release until counsel has reviewed the coverage map and unresolved policy conditions.

This article is general information, not legal advice, and does not create an attorney-client relationship. Legal citations should be verified against the primary source before you rely on them.