• For facilities who bill using the UB-04 (including hospital-based occupational clinics), is a medical narrative report required to be attached?

  Yes, a medical narrative report is required to be attached to the UB-04 and should include the three elements (depending on the provider's specialty): the patient's work status, causal relationship and temporary impairment percentage.

• If I have a question on the CMS-1500 initiative, how can I get more information?

  Current news, FAQs, technical requirements and other resources can be found on the CMS-1500 Initiative section on the Board's website. If you have additional questions, please send an email to CMS1500@wcb.ny.gov. Questions posed to the dedicated mailbox will be promptly acknowledged. Responses will be posted to the FAQ section of the website regularly for the benefit of all stakeholders.

• Do all CMS-1500 submissions require a narrative or attachment?

  Yes, all CMS-1500 submissions (whether submitted through a clearinghouse (XML submission partner) or sent directly to the Board) require a medical narrative and/or attachment. The Board has also developed a medical narrative report template, which may be completed for each provider's submission of the CMS-1500. A copy of the template and the associated narrative requirements can be found on the CMS-1500 Requirements web page.

  XML submission partners have been instructed to reject CMS-1500 submissions that are not accompanied by the required medical narrative and/or attachment.

• Does the CMS-1500 data need to be in the same format for submission to the payer as it is to the Board?

  No, the Board has specific technical requirements for the electronic transfer of the CMS-1500. The payer's requirements for electronic transfer may be different. Payer requirements should be confirmed with them.

• Is the C-4.3 being replaced with the CMS-1500?

  No, the C-4.3 will NOT be replaced by the required submission of the CMS-1500.

• Will a paper CMS-1500 be accepted by the Board?

  The Board will accept the paper CMS-1500 but strongly encourages electronic submission the XML submission process.

• Where are the descriptions of the fields for the CMS-1500 located?

  The CMS-1500 Field Matrix (Excel) details the box-by-box descriptions.

• Are there any anticipated changes for facilities that bill on the UB-04?

  There are no anticipated changes at this time for facilities that bill using the UB-04.

• How will EOBs/EORs be transmitted from the payer to the medical provider?

  Payers are required to submit EOBs/EORs electronically to their XML submission partners upon adjudication of the associated electronic CMS-1500. If the CMS-1500 was NOT submitted electronically, the payer may send the EOB/EOR to the medical provider by any other mutually agreed upon method. Payer EOBs/EORs (or X12 835 transactions) will be required to use specific CARC codes to identify the reason for the objection.

• What methods can be used to submit the CMS-1500?

  It is preferred that providers use electronic submission through the XML submission process; however, the Board's Forms webpage provides additional options to submit the CMS-1500 and its related medical narrative report to the Board. Medical bills are not sent through the Board's Medical Portal.

• Will there be a list of payer FEINs on the Board website?

  There will not be a list of FEINs on the Board's website.

• If there is no payer or the payer is undetermined, how will we submit only to the Board?

  The provider's office should obtain the employer's name and address from the patient. If they are unaware of the correct entity they work for, they should contact their human resources office or supervisor. In New York State, employers are required to post the Notice of Compliance – Workers' Compensation Law (Form C-105) in a conspicuous place in the workplace identifying the employer's workers' compensation insurer name, address, phone number and policy number.

  The provider can use the Employer Coverage Search app to search for the employer's insurer.

  If a provider is still unable to determine who the payer is, the form may be submitted to the Board through one of the options found under Sending Information to the Board

• If EOBs/EORs will be coming electronically, how will payments be made? Will checks be sent with no EOB/EOR or will a copy of an EOB/EOR be sent with payments?

  The Board is not mandating a change to the payers' payment method.

• Who pays the XML submission partner for their services?

  The party utilizing the XML submission partner services would pay them based on the agreement they have with each other.

• What methods can be used to submit the CMS-1500?

  It is preferred that providers use electronic submission through the XML submission process; however, the Board's Forms webpage provides additional options to submit the CMS-1500 and its related medical narrative report to the Board. Medical bills are not sent through the Board's Medical Portal.

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• Will insurers accept black and white copies of the CMS-1500 form, or is the original red CMS-1500 form required?

  Insurers should accept black and white copies of the CMS-1500. The original red CMS-1500 is not required. The resolution of the CMS-1500 form must be sufficiently clear to allow for optical scanning by payers and the Board.

• In the "Listing of Providers Authorized to Submit XML Data" report, does the column labeled "Currently Authorized" mean the provider is authorized to submit XML data or does it mean they are WCB authorized?

  The column titled "Currently Authorized" is in reference to WCB Authorization. Being listed on this report signifies authorization to submit XML data.

• Field 3 (patient's birth date, gender) on the CMS-1500 only allows for the selection of male or female. What is the correct way to identify a patient's birth sex if neither of these options are the preferred choice?

  This is an optional field which should be completed if known. If unknown or male/female is not the preferred choice, the field should be left blank.

• Do I need to complete a new XML Submission Agreement to submit the CMS-1500 electronically even though I already completed one to submit the EC-4NARR?

  No, all providers who have already completed an XML Submission Agreement to submit XML data to the Board do not need to complete a new agreement to begin submitting the CMS-1500 electronically.   Listing of Providers Authorized to Submit XML Data (MS Excel)

• I'm a provider who would like to start submitting the CMS-1500 and required medical narrative and/or attachments. Do I need to register with the Workers' Compensation Board first?

  Before the Board will accept electronic submission of CMS-1500 forms through the XML forms submission process, health care providers must first complete the online Medical Portal registration process and then accept the terms of the legal agreement by selecting the "Agreement for XML submission of CMS-1500" found under the Billing section of the Medical Portal.

• The clearinghouse that I use is not registered as a Workers' Compensation Board XML submission partner. How can I submit the CMS-1500 using the XML submission process?

  Clearinghouses are encouraged to become XML submission partners. Clearinghouses interested in becoming an XML submission partner will need to register first with the Board. All submission partners must test the CMS-1500 XML submission and be approved prior to implementation. However, if your clearinghouse does not wish to become a submission partner directly, they may work with one of the approved XML submission partners.

• Where can I obtain insurer information for billing purposes?

  You should obtain the employer's name and address from the patient. If they are unaware of the correct entity they work for, they should contact their human resources office or supervisor. In New York State, employers are required to post the Notice of Compliance - Workers' Compensation Law (Form C-105) in a conspicuous place in the workplace identifying the employer's workers' compensation insurer name, address, phone number and policy number.

  You may also obtain insurer information by using the Employer Coverage Search app on the Board's website.

• Will there be any CMS-1500 requirements for chiropractors?

  There are no unique CMS-1500 requirements specifically for chiropractors. Chiropractors should utilize the initial and subsequent narrative report requirements as shown on the CMS-1500 Requirements page.

• How do I become a Board authorized provider?

  Instruction for how to Apply to Become an Authorized Provider

• How do I know if I have previously signed up to submit medical bills electronically?

  Listing of Providers Authorized to Submit XML Data (MS Excel)

• How do I know which clearinghouses are planning to become CMS-1500 XML submission partners?

  The Board has published a listing of clearinghouses who are interested, testing or approved to become an XML submission partner for the CMS-1500.

• Will the Expanded Provider Law have any effect on how I submit the CMS-1500 via XML?

  Licensed clinical social workers, nurse practitioners, acupuncturists, physician assistants, occupational therapists and physical therapists must bill as the rendering provider. Before the Board will accept the electronic submission of CMS-1500 forms through the XML forms submission process, providers must first complete the online Medical Portal registration process and then accept the terms of the legal agreement by selecting the "Agreement for XML submission of CMS-1500" found under the Billing section of the Medical Portal.

• What are the requirements for the TIFF-formatted medical narrative and image of the completed CMS-1500?

  All of the images must be legible and of good quality. Specific requirements that the upload process will check for and fail if not met include:

  • TIFF4 Format (aka TIFF using 'CCITT Group 4 Fax' compression)
  • Fill Order must be 'Most Significant Bit (MSB) to Least Significant Bit (LSB)'
  • 'Single strip' images only
  • No tiled images allowed
  • 200 dpi
  • Black and White only (color depth: 1 bit)
  • One image per file (no multi-page TIFF files allowed; a duplex document should be converted to two image files)

• How should CMS-1500 bills be submitted for surgery when the surgeon has been assisted by another physician, nurse practitioner, or physician assistant?

  • Assistance by physician assistant or nurse practitioner
  • The surgeon's rating code should be entered in field 19. The surgeon's license number and NPI should be entered in field 24J and the bill should be signed by the surgeon in field 31.
    • Modifier 83 is to be used in field 24D to identify assistant services provided by a physician assistant or nurse practitioner.
    • CMS-1500 is submitted by the surgeon only-indicating codes performed by the NP/PA with Modifier 83.
  • Assistant surgeons
  • Modifier 80 would be used to identify surgery assistant services provided by a physician. The name, license number and NPI of anyone providing surgery assistant services should be included as part of the attached medical narrative.
    • The surgeon submits CMS-1500 bill for the codes they performed.
    • The assistant surgeon submits CMS-1500 bill for the codes they performed-indicating with Modifier 80.
    • The surgeon must include why an assistant was necessary, and what work performed in their narrative/operative report.
  • Examples of how different types of providers should fill out the CMS-1500 can be found on CMS-1500 Requirements webpage.
  • Also see the Workers' Compensation Medical Fee Schedule for applicable Surgical Ground Rules and discussion of modifiers.

• What methods can I use to send the CMS-1500 to the XML submission partner?

  Providers can send the CMS-1500 to their XML submission partner in whatever method is agreed upon between the two parties (EDI, mail, fax, email, portal, etc.).

• What should I do in situations where I have received acknowledgment of my bill having been accepted by the payer, but I have not yet been paid?

  Once 45 days have passed subsequent to the payer's acknowledgement of the medical bill, the provider may submit online using OnBoard a Request for Decision on Unpaid Medical Bill(s) (Form HP-1.0) if they haven't been paid. Bills should not be resubmitted (this will restart the clock and offer the payer another 45 days to respond/pay).

• Are there specific requirements for durable medical equipment (DME) suppliers submitting a CMS-1500?

  Durable medical equipment suppliers should include their eight-digit Medicaid Management Information System (MMIS) number in field 24J (shaded section) of the CMS-1500 and/or on the medical narrative attachment when submitting the CMS-1500 to an XML submission partner.

• We are a small medical practice that uses a third-party administrator to submit our workers' compensation bills. Who is required to register for XML submission, the third-party administrator, or our providers?

  The treating provider, not the third-party administrator, must register for XML submission.

• Do all providers have to be Board authorized to submit the CMS-1500?

  No. Certain urgent care, emergency room, out-of-state and durable medical equipment providers are not required (and some are not eligible) to be Board authorized for treatment. However, all providers are required to register for XML submission in order to electronically submit medical bills through an XML submission partner.

• If there are two ordering providers for different service lines on the CMS-1500, where should the second ordering provider's information be captured, since only one can be entered in Field 17?

  One provider's information (name, state license number and National Provider Identifier) should be listed in Fields 17, 17a, 17b and the other should be listed in the attached medical narrative.

• How will I know when my bill has been accepted by the payer?

  By submitting electronically, there is verifiable acknowledgement data on record to show when the bill was received by the payer. The payer must remit payment within 45 days from the acknowledgement date.

• Will the required time frames for submitting the medical reports change as a result of this initiative?

  The time frames for submitting medical reports to the Board and the payer (set forth in NYCRR 325-1.3) are not changing as a result of this initiative. The following timeframes are still required:

  • Initial CMS-1500 (formerly the C-4, OT/PT-4 or the PS-4): within 48 hours of first treatment;
  • Subsequent CMS-1500 (formerly the C-4.2, OT/PT-4 or the PS-4): 15 days after first treatment, and thereafter for continuing treatment: after each follow-up visit scheduled when medically necessary but not more than 90 days apart.

• Will all payers accept a CMS-1500?

  All payers are required to accept paper or electronic (can be EDI or other agreed-upon format) CMS-1500.

• What is the email address to submit claims?

  Medical bills/reports may be submitted to the Board by email at wcbclaimsfiling@wcb.ny.gov. However, the Board encourages providers to partner with a clearinghouse for the XML submission of the CMS-1500.

• Will providers be able to see patients' medical records through clearinghouses?

  Clearinghouses provide their own array of services to medical providers with whom they contract. Please confirm services offered directly with the clearinghouse.

• Will clearinghouses be using medical records from Medicare, Medicaid or private insurers to dispute WCB claims?

  Data sharing outside of the workers' compensation system is not part of the CMS-1500 initiative. However, please note that providers should not be billing workers' compensation payers and other insurers simultaneously for the same services. According to Workers' Compensation Law 13(a), employers shall promptly provide for an injured employee such medical, dental, surgical, optometric or other attendance or treatment.

• Where on the CMS-1500 form does the provider's WCB authorization number and rating code belong?

  The provider's authorization number and rating code are entered in field 19 on the CMS-1500 form. Please see the Field Matrix on the Requirements page to determine the information required for each field of the form.

• Do patients with a lifetime approved benefit need to have medical narrative attachments?

  Medical narratives and/or attachments are required for all medical bills, regardless of whether the patient has a permanent classification.

• Will there be an area on the Board's website where narratives could be uploaded manually if need be?

  Medical reports can be uploaded using the Web Upload Service.

• When submitting electronically, would the provider need to use the same clearinghouse (XML submission partner) as the payer?

  The provider will not need to use the same clearinghouse as the payer. Clearinghouses have multiple agreements with other clearinghouses to pass bills electronically ensuring timely submission to payers.

  • Payers' XML Submission Partner Lookup

• If the claim is rejected can the patient be billed?

  If the bill is rejected by the payer, it cannot be billed to the patient. Section 13-f of the Workers' Compensation Law prohibits providers from billing workers' compensation patients.

• When should a provider submit an initial medical bill/report for treatment to the payer and the Board?

  The decision as to whether an initial medical treatment must be submitted to the Board and the payer is a medical decision. The medical provider should submit the bill/report to the XML submission partner when the patient has a reportable workers' compensation injury beyond rendering first aid. It is not relevant under the WCL that an employer wishes to pay for medical treatment directly.

• Will we need to make system and or workflow changes to send the Board's proprietary data element for the provider WCB Rating Code and WCB Authorization Number, since they are not supported in the X12 837?

  No, you will not need to make any systems changes to your exiting workflow process. The XML submission partner will handle the electronic indexing to the Board's field table matrix to capture the WCB Rating Code and WCB Authorization Number to populate the CMS-1500 form and submit a compliant XML with documentation to the Board on your behalf.

• We currently submit attachments to our clearinghouse for Property and Casualty Commercial payers today. Are there any attachment format changes we will need to make to comply with the NYS Workers' Compensation Board attachment requirements?

  No, you should not need to make any changes on how you are sending attachments to your clearinghouse. Approved XML submission partners can handle the attachment format conversion process on your behalf to comply with the Board's format requirements.

• What is the CMS-1500 form used for?

  The CMS-1500 is a universal claim form used by medical providers to bill the Centers for Medicare and Medicaid Services (CMS) as well as health insurers.

• If an insurer is not prepared to accept XML or if they are not sending providers an EOR/EOB within 45 days, how do we escalate?

  Please contact CMS1500@wcb.ny.gov to alert us to payers who are not complying with CMS-1500 initiative requirements.

• Can you reject a CMS-1500 form for a causal relationship? What are the criteria for judgment of work-related causation that the board will be using with the CMS-1500 form?

  All CMS-1500 submissions require a medical narrative attachment. There are three elements that should be included on most narratives: 1) the patient's work status; 2) causal relationship; and 3) temporary impairment percentage. The CMS-1500 may be rejected by the payer if a medical narrative attachment is missing. The CMS-1500 initiative does not change anything related to a payer's assessment of causal relationship.

• Should the CMS-1500 form be used to bill for medical testimony?

  The CMS-1500 may be used for medical testimony with CPT code 99075. Bills for medical testimony are outside of the regulations for medical services billing, thus are not subject to the 45-day period to pay or object to the bill. There is no CARC code and payers should not file a legal or valuation objection to payment of these fees.

• Do CMS-1500 forms submitted electronically still need to be sent to the Board?

  No, when providers submit the CMS-1500 electronically through an XML submission partner, the XML submission partner will submit to the insurer and the Board.

• What if the provider leaves information out of the CMS-1500 narrative?

  A medical narrative report may be found legally defective when it is missing necessary elements.

• Can occupational therapists/physical therapists submit a temporary impairment percentage, or will therapists be excused from inputting the percentage on the CMS 1500 form?

  Occupational therapists and physical therapists are excluded from commenting on causal relationship and temporary impairment percentage. Medical narrative requirements can be found on the CMS-1500 Requirements page.

• Will the Board no longer accept faxed claims?

  The Board no longer accepts faxed claims. In addition to electronic submission through an XML submission partner, claims may also be sent by mail, email, or web upload. Detailed information can be founded on the Forms page.

• Do you have a list of payers that are not going to accept electronic claims?

  Effective, October 1, 2021, all workers' compensation payers must electronically accept the CMS-1500 (can be EDI or other agreed-upon format).

• Do providers also need to apply specified narrative requirements to daily progress notes along with their CMS-1500 form submission?

  Yes, detailed information on the medical narrative attachment requirements can be found on the CMS-1500 Requirements page.

• How do I submit electronically with the narrative attached?

  You should coordinate the process and format for electronic submission with your XML submission partner. Approved, XML submission partners can handle the attachment format on your behalf to comply with the Board's requirements.

• Does a SOAP note (which is generated for treatment visits and does not include all the information during a re-exam) meet the requirement of a "narrative" with the CMS-1500?

  Most Medical narrative attachments should include three elements: 1) the patient's work status; 2) causal relationship of the injury to the patient's work activities; and 3) temporary impairment percentage. A medical narrative report may be found legally defective if these elements are missing.

• Do providers hire an XML partner, or does each insurance company hire their own and the provider uses that partner to submit their claims?

  Providers are expected to partner with an approved XML submission partner who will ensure that the medical bill and narrative attachment are sent and accepted by the correct payer.

• Is there any penalty for not billing through XML?

  No, XML submission is strongly encouraged, although not required.

• Will DME suppliers be required to bill using a CMS-1500 form and to provide a narrative (even if the DME supplier does not perform an examination of the patient)?

  Yes, DME suppliers will be required to bill using the CMS-1500. The attachment that accompanies the CMS-1500 should include a copy of the physician's prescription (order) for the item(s) and proof of certification of enrollment in the NYS Medicaid program including the Medicaid Management Information System (MMIS) number of the DME supplier. Narrative/attachment requirements for all provider types may be found on the CMS-1500 Requirements page.

• If our office will decides to submit paper CMS-1500s, do we still need to register for the Medical Portal?

  Yes, health care providers are encouraged to register for the Medical Portal. The Medical Portal will enable health care providers to apply to become Board-authorized, renew Board authorization and/or update practice information, get training on important topics relevant to the user's role, access lookup tools for the Board's Medical Treatment Guidelines and Drug Formulary, and execute the User Agreement to submit CMS-1500 medical bills through the XML submission process. Additionally, health care providers will use the Medical Portal to access OnBoard: Limited Release and will be able to delegate users to assist with submitting prior authorization requests and Request for Decision on Unpaid Medical Bills (Form HP-1.0).

• Can a provider submit a fully completed Form C-4 or Form C-4.2 as the attachment to the CMS-1500 to demonstrate medical necessity and compliance with the MTGs?

  Form C-4 and Form C-4.2 are discontinued as of July 1, 2022. All CMS-1500 submissions require a medical narrative attachment. The Board has developed a medical narrative report template which may be completed for each provider's submission of the CMS-1500. A copy of the template and the associated narrative requirements can be found on the CMS-1500 Requirements page.

• If our office bills electronically, will each insurer have their own electronic payer ID?

  Insurers and employers who have been approved to self-insure for worker's compensation benefits in New York State are assigned a 7-character identification number which can be found on the Payers' XML Submission Partner Lookup webpage. Additionally, approved XML submission partners/clearinghouses are knowledgeable about the correct Payer ID needed to deliver electronic medical bills to the payer.

• Who should I contact if my CMS-1500 forms are not being sent to the Board by my clearinghouse?

  Please notify the Board by sending an email to CMS1500@wcb.ny.gov.

• Does each provider affiliated with a group practice need to register individually for the Medical Portal and sign up for XML submission of the CMS-1500?

  Yes, each health care provider who would like to submit the CMS-1500 using the XML submission process must first complete the online Medical Portal registration. After logging into the Medical Portal, providers who have not already signed up for XML submission of the CMS-1500 will see a link under the Billing section "Agreement for XML submission of CMS-1500".

• If the C-4.3 is not being replaced by the CMS-1500, will I be able to submit the C-4.3 electronically using an XML submission partner?

  The CMS-1500 form must be used to submit medical bills for MMI/permanency evaluations, whether the CMS-1500 is being submitted in paper form or electronically using an XML submission partner. To do so, medical providers should:

  • Only use CPT codes 99243 or 99245
  • Only use ONE CPT code (99243 or 99245) on the medical bill (a "completed medical bill" is defined as the CMS-1500 form, and the accompanying medical narrative, which in this instance is the CMS-1500 form and the attached C-4.3 form)
  • Attach a completed C-4.3 to the CMS-1500 form as the medical narrative, as noted above
  • Do not separately send a C-4.3 to the Board, as these will be rejected

• How should the CMS-1500 form (paper version) be completed when there are more than 6 procedures, services or supplies on one date of service?

  If there are more than six line items for one date of service, you may submit multiple CMS-1500 forms together with the total charge amount appearing only on the last form.

• How can I electronically submit bills for apportioned claims?

  When submitting an apportioned bill, providers should clearly state on the medical narrative attachment that it is an apportioned bill and include the other WCB case number(s) and/or insurer claim number.

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• I'm a medical billing clearinghouse and would like to register with the Worker's Compensation Board to become an XML submission partner. Who do I contact to register?

  Clearinghouses interested in becoming an XML submission partner will need to complete an online registration with the Board.

• Will there be a testing phase prior to implementing the submission of CMS-1500 in XML format?

  Yes, you will be required to complete a testing phase to verify that you can submit a valid CMS-1500 to the Board.

• Is there an XML schema available?

  A CMS-1500 XML schema is available on the XML Form Submission Schemas, Documentation and Samples webpage.

• Will the 837P or 837I format with attachment be accepted in place of the XML format?

  The 837P or 837I will NOT be accepted in place of the XML format.

• Where can I find the specifications for attaching provider narrative items (initial and follow-up reports) in XML electronic submission?

  Information regarding submitting attachments can be found on the XML Forms Submission Restrictions/Requirements page.

  The narrative attachments need to be TIFF modeled after the narrative template requirements found on CMS-1500 Requirements page. If the template is utilized by the provider, it should precede other medical narrative documents.

• Besides the XML rendering for the CMS-1500, what must be contained in the XML file transmitted to the Workers' Compensation Board?

  Each CMS-1500 submitted via XML must include a TIFF-formatted medical narrative and a TIFF-formatted image of the completed CMS-1500.

• Do all clearinghouses need to become XML submission partners?

  No, only those clearinghouses that are sending XML files to the Workers' Compensation Board need to become XML submission partners.

• What will be included in the test plan?

  There will be two components to the test plan: 1) Preliminary; and 2) Parallel. Preliminary testing is required to allow the XML submission partner to demonstrate to the Board that they can construct a submission that is properly formatted. It is not necessary to use production data for preliminary testing. Parallel testing will occur after successful preliminary testing. This is to ensure that data received electronically from the provider is properly mapped to the submitted XML file and CMS-1500 image, and that the same information (mapped fields) submitted by the provider on the current production form is contained in the parallel test submission. Before the parallel test phase begins, the submitter needs to identify providers and payers to participate in the testing phase with them. Additional details of the test plan are available in the CMS-1500: A Guide for New XML Submission Partners.

• Where do the XML submission partners obtain the WCB authorization number and rating code?

  Provider WCB authorization numbers and rating codes can be found on the Listing of Providers Authorized to Submit XML Data (MS Excel).

• How will I know the payer acknowledgment date if the CMS-1500 has not been sent electronically to the payer?

  The payer acknowledgment date will not be required for paper submissions.

• What is the timing of submission of the CMS-1500 to the Board?

  The CMS-1500 forms and medical narrative reports should be submitted to the Board immediately upon acknowledgment by the payer and no later than seven business days after receipt from the treating provider.

• If any non-required field is unknown to the XML submission partner, e.g., claimant's Social Security number, how should this be transmitted to the Board? Are there default values that should be used in these cases such as "Unknown" or "999999999"?

  If the XML submission partner does not have the data for a non-required field, the field should be left blank.

• What are the requirements for the TIFF-formatted medical narrative and image of the completed CMS-1500?

  All of the images must be legible and of good quality. Specific requirements that the upload process will check for and fail if not met include:

  • TIFF4 Format (aka TIFF using 'CCITT Group 4 Fax' compression)
  • Fill Order must be 'Most Significant Bit (MSB) to Least Significant Bit (LSB)'
  • 'Single strip' images only
  • No tiled images allowed
  • 200 dpi
  • Black and White only (color depth: 1 bit)
  • One image per file (no multi-page TIFF files allowed; a duplex document should be converted to two image files)

• Since NPI numbers will be used to validate electronic submission of the CMS-1500, how can I ensure that the providers we are supporting have submitted their NPI to the Board?

  Please refer to the Listing of Providers Authorized to Submit XML Data (MS Excel) for information on providers who have been approved for XML submission. If the Board has not yet received an NPI number for a particular provider, it will be notated in column D.

• When there is more than one XML submission partner involved in the transmission of a bill from the provider to the payer, which party is responsible for submitting the CMS-1500 form to the Board?

  Typically, the XML submission partner closest to the provider would submit the CMS-1500 form to the Board. However, there may be other instances where the XML submission partners have an agreement regarding who will be submitting to the Board. It is important that processes be in place to avoid multiple submissions of the same bill to the Board.

  • Payers' XML Submission Partner Lookup

• How will we determine which Insurer ID (W Number) to include on the CMS-1500 form?

  The Insurer ID (W Number) is a situational field and should be included when known. This information should be provided by the payer. Each insurer has a unique Insurer ID. In situations where there is a one-to-one relationship between the insurer and payer, the Insurer ID should be populated in Field 0 of the CMS-1500 form. If more than one insurer is associated with a payer, the Insurer ID may be unknown and Field 0 should be left blank.

• When there is more than one XML submission partner/clearinghouse involved in the transmission of a bill from the provider to the payer, can the treating provider be billed extra for transmission of the CMS-1500 form from the payer's clearinghouse to the payer?

  When a treating provider utilizes the services of a Board-approved XML submission partner/clearinghouse, the provider is obligated to pay for the initial transmittal of the CMS-1500 form to the payer and the Board. Additional costs cannot be billed to the provider. The payer is obligated to pay for any fees associated with transactions through its XML submission partner/clearinghouse if the payer does not contract with the same XML submission partner/clearinghouse used by the treating provider.

• Why do some provider names appear more than once on the listing of providers authorized to submit XML Data?

  There may be instances where a provider name appears more than once on the Listing of Providers Authorized to Submit XML Data. These are unique providers who have the same name but different NPI and license numbers.

• How many documents can an XML Submission Partner submit per file to the Board?

  There is a limit of 1,000 documents per file submission sent to the Board. The XML Forms Submission app creates one batch to go into P8 Imaging for each zip file submitted. It is the P8 intake that allows a set limit of 1,000 documents per batch.

  If an XML Submission Partner has more than 1,000 documents to send to the Board, they should submit multiple batches per day with different names.

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• When completing a C-8.1B and the objection reason requires a CARC with an associated RARC, what should be entered?

  Please review the X12 code sets and select the most appropriate, valid CARC/RARC code combination. Do not enter your own codes.

  CARC/RARC codes may be found at:

  • CARC codes
  • RARC codes

• When the Board identifies new CARC/RARC codes that payers must use when objecting to payment of medical bills, how much lead time will payers have to implement the new codes?

  Payers will have up to 90 days to implement new CARC/RARC code scenarios from the date the Board publishes the CARC/RARC codes.

• What should a payer do if they are withholding payment because they do not have a form W-9 (Taxpayer Identification Number and Certification) on file for the provider?

  Payers may use CARC 252 (an attachment or other documentation is required to adjudicate this claim/service), along with RARC N836 (provider W-9 or payee registration not on file) to report that payment is withheld pending receipt of the provider's federal tax identification number on form W-9. NOTE: This should be used on the EOB only, and payers should not file Form C-8.1B since it is not a true legal objection.

• Since there is no selection on the C-8.4 to use when there is a Preferred Provider Organization (PPO) reduction, how should the C-8.4 be completed when there is a PPO reduction AND another valuation reduction?

  A C-8.4 is NOT required when the insurer reduces the amount of the bill pursuant to a contractual agreement with the provider (i.e., network or PPO discount). However, if there are other valuation reductions in addition to the PPO discount, the insurer should submit a C-8.4 noting the other valuation objection(s) (i.e., not in accordance with ground rule limitation or inappropriate for clinical situation) in Section C. Section B should be completed as follows:

  • Field 4 Amount of Bill - Enter amount billed to the insurer for services rendered.
  • Field 5 Amount Paid - Enter amount the insurer actually paid.
  • Field 6 Amount in Dispute - Enter disputed amount consistent with objection selected (understanding that Field 4 minus Field 5 may not equal Field 6).

• With regards to the filing of C-8.1B and C-8.4 simultaneously, if the C-8.1B issue is resolved via a Notice of Decision by the Board, and the C-8.4 issue has not been resolved by either arbitration or medical director's office, is the insurer required to process the claim?

  The Board only reviews C-8.4 objections if a provider has filed an HP-1.0. Thus, if a C-8.1B objection is resolved in the provider's favor, the insurer should process the payment at the amount reported on the C-8.4 (i.e., taking into account any valuation objections the payer timely submitted to the Board on the C-8.4).

• Will penalties be assessed if a C-8.1B or C-8.4 objection is filed when they are not required to, including the following 4 scenarios (1 – Amount billed for CPT code exceeds the amount designated by the applicable medical fee schedule and insurer pays the bill at the medical fee schedule amount; 2 – Payer reduces the amount of bill to 12, 15 or 18 relative value units for evaluation services and modalities, as set forth in the applicable medical fee schedule; 3 – Payer reduces the amount of the bill pursuant to a contractual agreement with the provider; and 4 – There is a duplicate bill.)?

  The Board will monitor payer submission of unnecessary C-8.1B and C-8.4 and may impose penalties in the future.

• When a payer reduces the amount paid on a medical bill due to a resolved apportionment issue, is a C-8.1B required to be filed?

  No, a C-8.1B is not required but CARC P32 should be included on the EOB/EOR sent to the provider.

• What is the correct way to complete a C-8.4 when the reasons for the objection include a Medical Fee Schedule reduction AND any other valuation objection? For example, if a medical bill was received for $20,000 and the amount paid was $6,000 due to reductions: 1) $10,000 Fee Schedule; 2) $3,000 Unnecessary or Excessive Hospitalization; and 3) $1,000 Improper CPT codes, would it be correct to enter $4,000 in box 16 as the amount in dispute?

  No, the amount in dispute would be $14,000 which would include the $10,000 for the Medical Fee Schedule reduction as well as any other objections ($3,000 Excessive Hospitalization plus $1,000 Improper CPT Codes). Please note, if the ONLY valuation objection is for the Medical Fee Schedule reduction, then a C-8.4 is not required and should not be submitted to the Board.

• What information will a payer be required to submit to the XML submission partner upon receipt of a CMS-1500 bill?

  The payer must submit the following information to the XML submission partner:

  • Insurer Acknowledgment Date [YYYY-MM-DD]
  • Insurer ID - (W Number) - Should be populated when there is a one-to-one relationship between the insurer and payer. If more than one insurer is associated with a payer, the Insurer ID may be unknown and left blank.
  • WCB Case Number (when technically feasible)

• If a payer has no claim on record for a specific injury date, is it required to accept a CMS-1500 from an XML submission partner?

  Yes, a payer may not reject a CMS-1500 from the XML submission partner if a claim (FROI) has not yet been received.

• Are all payers required to accept the CMS-1500 electronically?

  Yes, as of October 1, 2021, all payers must electronically accept the CMS-1500 (can be EDI or other agreed-upon format). If payers fail to comply by the deadline, they may be subject to penalties as set forth in WCL §§ 25(3)(e) and 114-a(3).

• Will the payer be required to issue Form C-8.1B for any bill missing a narrative or will the EOBs/EORs stating the omission be sufficient?

  The Board has not changed the process to object to a legally defective bill. Note: All CMS-1500 submissions require a medical narrative and/or attachment. XML submission partners will reject CMS-1500 submissions not containing a medical narrative.

• Should a payer submit an objection (and CARC code) to the Board when reducing a provider's medical bill to align with the Relative Value Unit (RVU) limitations in the medical fee schedule?

  No, the payer may reduce the amount of the bill to 12, 15 or 18 RVUs for evaluation services and modalities, as set forth in the applicable medical fee schedule. The payer should not submit an objection to the Board. This RVU reduction typically applies to chiropractic services, physical therapy modalities, occupational therapy modalities and acupuncture services.

• How will payers know what XML submission partner the provider is using?

  Payers will be responsible for returning an acknowledgement of receipt back to the XML submission partners from which they received the CMS-1500 billing data/medical narrative attachments.

• At what point does the 45-day rule start for payment?

  The payer must remit payment (or object to payment of the bill) within 45 days from when the bill is received by the payer's XML submission partners or the payer themselves (whichever is earlier).

• We are a third-party administrator who handles claims for self-insured employers and insurance carriers. Will our information be captured anywhere on the CMS-1500?

  Yes, third-party administrator information will be captured in CMS item 0 (payer name, address, city state and zip). If known, the Insurer ID (W number) should be entered in item 0 (Insurer W#).

• How do I know which clearinghouses are planning to become CMS-1500 XML submission partners?

  The Board has published a listing of clearinghouses who are interested, testing or approved to become an XML submission partner for the CMS-1500.

• Is there a requirement that the CARC/RARC codes and CARC/RARC code descriptions be included on insurer EORs/X12 835 transactions?

  The CARC/RARC codes indicated on the C-8.1B/C-8.4 forms will be required to be included on the EOR (or EDI X12 835) sent to the provider. An EOR with matching CARC/RARC codes should also accompany C-8.1B and C-8.4 forms sent to the Board.

• What is the purpose of the seven-day waiting period on acceptance of a CMS-1500 when there is no claim on file?

  The intent of the seven-day period is to allow the providers, XML submission partners, and payers to work collaboratively during this time to make corrections to the electronic transmission allowing it to flow through the process without error. A payer may not unilaterally reject a CMS-1500 from the XML submission partner if a claim (FROI) has not yet been received. The Board considers receipt of a medical bill to be notice of a possible claim. Payers are expected to complete an investigation of the bill within the seven-day period to determine if there is a claim and they are the correct payer. Payers will be required to accept the bill if the investigation is not completed within the seven-day period.

• When the submission of the CMS-1500 becomes mandatory in July 2022, will payers be required to accept and review CMS-1500 forms submitted by out-of-state, non-authorized providers or should they be rejected upon receipt?

  Payers will be expected to accept and review CMS-1500 submitted by out-of-state, non-authorized providers (whether received electronically or on paper) as it is an accepted national standard.

• Will payers be required to electronically send the C-8.1B or C-8.4 forms through the XML Submission Partner?

  No. The Board is not requiring the C-8.1B/C-8.4 to be sent electronically through the XML submission partners. Only the EOB/EOR will be required to be sent electronically through the XML submission partners to the provider (in scenarios where the provider's medical bill was electronically transmitted).

• What methods can be used to submit the C-8.1B/C-8.4 to the Board?

  Payers can continue to use online submission, mail or email to submit the C-8.1B/C-8.4 to the Board. A copy of the EOB/EOR that was sent to the provider (with corresponding CARC codes) will need to be submitted with the C-8.1B/C-8.4.

• Will the payer be required to send the claimant and/or representative the C-8.1B/C-8.4 and/or EOB/EOR?

  Yes, the payer must send the C-8.1B/C-8.4 to the claimant and/or representative.

• How long do payers have to accept or reject an electronic medical bill from an XML submission partner?

  Payers must acknowledge electronic medical bills within seven (7) business days of receipt.

  Effective October 1, 2021, payers must accept an electronic medical bill from an XML submission partner when it is transmitted using EDI or another format agreed upon with the XML submission partner. The date the medical bill is accepted into the payer's adjudication system is referred to as the acknowledgement date. Such acknowledgements will be forwarded from the XML submission partner back to health care providers and the acknowledgment date will be incorporated in the XML files sent by the XML submission partner to the Board.

  As a reminder, receipt of a medical bill (whether on paper or digital) is considered notice of a potential claim. Thus, insurers must investigate existence of a claim if one has not yet been filed. Medical bills should not be rejected solely due to lack of a claim on file.

  A rejection of an electronic bill must be made within seven business days of the bill's initial transmission date from the medical provider's XML submission partner. Mandatory fields can be found in the Board's CMS-1500 Field XML Schema.

  Note: The only valid reasons a payer can reject an electronic bill from the designated XML submission partner are if a mandatory field is incomplete, an attachment is missing, or the insurer does not provide coverage to the employer.

• When payers begin sending EOBs/EORs electronically to providers using the X12 835 or other agreed-upon format, how does the Board expect to receive this information?

  The Board would only receive EOBs/EORs that are attached to a C-8.1B or C-8.4. These paper versions of the EOBs/EORs would be in a format similar to the Centers for Medicare and Medicaid Services' Standard Paper Remittance (SPR) and would contain the same CARC codes as those transmitted in the 835.

• Are we able to use the same 277CA Acknowledgment eBill workflow process, to notify the provider when there is not a claim match due to no policy on file and or missing information?

  Yes, you would use the same 277CA Acknowledgment process used today for eBill to notify the provider of the claim status, that includes if the transactions were accepted and or rejected with the appropriate claim status codes.

• Does the CMS-1500 form need to be submitted by the billing company?

  The CMS-1500 form is submitted by the provider or the provider's billing company to the payer (or, as the Board strongly encourages, to an approved XML Submission Partner who will transmit it to the payer and the Board).

• What about business days around holidays? We close for both Thanksgiving and the Friday after Thanksgiving and we usually close for two days around Christmas. Would it be seven business days or seven non-legal holiday business days?

  Electronic medical bills must be acknowledged by the payer within 7 business days. By definition, business days excludes State holidays, which are set forth in a Board Subject Number each year.

• Could you clarify the acknowledgement date when bills are sent to a PPO?

  If the PPO is the payer, then the acknowledgement date is the date the PPO received the bill.

• Regarding the narrative report, you indicated DME bills are part of the CMS-1500 form. If a DME provider does not submit a narrative report with the CMS-1500, is this considered to be rejected by a payer?

  An attachment is requirement for all CMS-1500 submissions. A DME supplier should include a copy of the physician's prescription (order) for the item(s) and proof of certification of enrollment in the NYS Medicaid program including the Medicaid Management Information System (MMIS) number of the DME supplier. Please check the CMS-1500 requirements page for attachment requirements.

• On the CMS-1500 form field 9a, the WCB Case # should be included by the provider. As a payer or clearinghouse, if that field is not filled in does that qualify for rejecting the bill?

  Field 9a is a situational field and should be included, when known. If left blank, it should not be rejected by the payer or clearinghouse.

• If a legal issue is raised on Form C-8.1B and the provider did not bill in accordance with fee schedule, will the payer have to file Form C-8.4 if the EOR reflects the billed amount was not in accordance with fee schedule?

  The C-8.4 is not required when the amount billed for the particular CPT code is in excess of the amount designated by the workers' compensation fee schedule and the insurer pays (or will pay, if found liable by the Board) the bill at the appropriate fee schedule amount.

• We are a medical bill review company with payer clients who do not use EDI but send their bills to us on an FTP site. We return the recommended payment information and an EOB/EOR to them. They send the EOB/EOR and the payment to the provider (we make no payments). Sounds like we will have to figure out some way to send them Form C-8.1B in their payment export as well. Am I understanding that correctly?

  The payer is responsible for filing Form C-8.1B (and C-8.4, if applicable) with the Board. The Form C-8.1B may be sent to the Board via email, web upload or on paper. Only the EOB/EOR is required to be transmitted back through an XML submission partner to the provider.

• If we are filing Form C-8.1B for the full amount of the bill for legal/MTG reasons, but are now expected to simultaneously issue Form C-8.4 and we identify a valuation reason for a specific line item only and not the entire bill, do we have to submit two EOBs/EORs? One showing the full denial (zero allowance) and the second one for our valuation reasons, in the event our denial is not found in our favor and must pay the bill after a judge's ruling?

  No, the Board expects that there would be one EOB/EOR that would include the codes for both objections, one for the legal objection and the other for the valuation objection. The medical bill would not be paid pending resolution of the legal objection by the Board. If found in favor of the provider, the payer would pay the provider the reduced fee equal to the previously filed valuation objection.

• Would we lose our opportunity to file Form C-8.4 if we file a legal objection (Form C-8.1B) for site not related, and it is later ruled that site is amended to the claim, therefore we must process the bill even though the bill is reduced per PPO contract?

  All legal and valuation objections should be filed simultaneously within 45 days of receipt of the medical bill. All objection reasons should be included on the EOB/EOR. No payment is required pending resolution of the legal objection.

• Will we still have to send forms to the Board, claimant, provider, and claimants attorney?

  The distribution requirements for Forms C-8.1B and C-8.4 have not changed. Please see the forms page for Insurers, Self-Insured Employers and Third-Party Administrators to confirm distribution.

• Does the new simultaneous objection procedure apply to denied claims?

  Our clients do not decide whether to challenge valuation issues until they have been found liable for the claim. There is no exception in the regulations for controverted, body part not covered, or any other legal objection. The valuation exception would need to be made at the same time as the legal objection.

• Objections made to medical bills for treatment rendered on or after the regulation's effective date must be made simultaneously. Can you please explain "simultaneously?"

  Simultaneously means that the Board must receive all legal and valuation objections on the required Forms C-8.1B and C-8.4, respectively, on the same day. The EOR/EOB sent to the provider (or through the XML Submission Partner) must be sent within 45 days, however, is not required to be on the same day as the Forms C-8.1B and C-8.4 are filed with the Board.

• Is the Board expecting that when an EOB/EOR is produced reflecting a reduction or rejection of a charge that Form C-8.1B or Form C-8.4 be issued simultaneously with that EOR, and we no longer have the 45 days to issue Form C-8.1B or Form C-8.4?

  If an EOB/EOR is issued for a reduction in charge to the appropriate fee schedule amount, a C-8.4 is not required. If there are other legal or valuation objections being made, then all objections (C-8.1B or C-8.4) must be made simultaneously within the 45-day period and an EOB/EOR must be attached to the C-8.1B or C-8.4 sent to the Board. The EOB/EOR may be sent directly to the provider (or through the XML Submission Partner)

• We are not the payer but do the bill review and fee scheduling for NY clients. To clarify, will we need to replace our message code reasons on the EOB/EOR's with the CARCs? May we use one of our message codes if there is not an applicable CARC?

  The Board expects the vast majority of legal objections to be covered by the standardized CARC/RARC code set. If a payer has a unique legal objection not reflected on the standardized CARC/RARC code set, they may select "other" on the Form C-8.1B and identify the applicable CARC code. Use CARC and RARC codes when objecting to payment of medical bills.

• Is the payer responsible for Form C-8.1B? If we are providing them with the EOB/EOR, do we have to fill out Form C-8.1B? Does Form C-8.1B go to the provider along with the EOB/EOR?

  Yes, the payer is responsible for submitting Form C-8.1B to the Board and other required stakeholders, including the provider. A copy of the EOB/EOR should be attached to the Form C-8.1B upon submission to the Board.

• Is the EOB/EOR generated by the bill review team and Form C-8.4 is completed by the claim examiner?

  The payer is required to submit Form C-8.4 simultaneously with Form C-8.1B (if applicable) to the Board.

• If more than one CARC/RARC is used on the EOR, is the payer required to indicate each CARC on Form C-8.4 checkbox, so long one is marked on Form C-8.4 checkbox, or is just one check permissible? For example: If line 1 is reduced to the fee schedule because the line charge is greater than the fee schedule, and the payer uses CARC P12 and line 2 is denied since the provider billed the invalid code, and we use CARC P13 plus RARC M51... does Form C-8.4 require us to check both boxes: "is excessive or not in accordance with fee schedule" and "uses improper CPT codes?" Can we just indicate one checkbox and be in compliance with the Board?

  In the above example, selecting one check box is not compliant. The CARC codes on Form C-8.4 should correspond with the objections selected on the EOB/EOR. The payer may use additional CARC & RARC codes on the EOB/EOR to further clarify the valuation objection (even when these CARC & RARC codes are not available to select on Form C-8.4).

• Please confirm that it is your intent to discontinue the Form C-8.1B and Form C-8.4 once electronic billing is fully implemented.

  The Board expects to eliminate the Form C-8.1B and the Form C-8.4 when electronic billing is fully implemented, including IAIABC's State reporting.

• Is there an expectation that the Form C-8.1B or C-8.4 be sent electronically to the provider through an XML submission partner?

  There is no requirement that Form C-8.1B or Form C-8.4 forms be sent electronically to the provider through an XML submission partner. However, insurers are required to send an electronic EOB/EOR back through the XML submission partner if the medical bill was received electronically from the XML submission partner. The XML submission partner will coordinate transmitting the EOB/EOR to the provider.

• If the Form C-8.1B and Form C-8.4 are not being sent electronically to the provider through an XML submission partner, how do insurers comply with the requirement that all objections to medical bills be made simultaneously?

  Effective November 1, 2021, the Board requires simultaneous filing of all objections to medical bills. The objections should be made on Form C-8.1B (legal objections) and/or Form C-8.4 (valuation objections) and should be sent to the Board at the same time, along with a copy of the EOB/EOR. There is not an online version of the Form C-8.4, so if there are both legal and valuation objections for a particular bill, they should be completed on the paper version of the form and submitted with the EOB/EOR to the Board.

• What will be the penalty for failure to attach an EOB/EOR to the Form C-8.1B and/or Form C-8.4?

  The Board will not impose a monetary penalty; however, the Board will find that the objection to be invalid. The insurer would be liable for payment of the full amount billed up to the maximum amount established in the applicable medical fee schedule.

• When filing Form C-8.1B, is Form C-8.4 supposed to reflect the amount that the insurer/TPA is objecting to on Form C-8.1B?

  When a payer files simultaneous legal and valuation objections on Forms C-8.1B and C-8.4, respectively, the amount in dispute on Form C-8.4 should be equal to the proposed reduction in the amount payable for the bill should the legal objection be resolved in the provider's favor.

• Will the payer be required to retain a Board-approved XML submission partner?

  Yes, all payers must designate at least one Board-approved XML submission partner from whom they will accept medical bills submitted by providers.

• For a bill processed through a network such as a Diagnostic Testing Network (DTN) or a Preferred Provider Organization (PPO), the provider bills the network directly on a Form CMS-1500. The network pays the provider according to the contracted rate and then bills the insurer for the service. Is the original bill that the provider submits to the DTN/PPO reportable to the Board or is only the resulting bill from the DTN/PPO to the insurer reportable to the Board through an XML submission partner?

  When a DTN/PPO is used by an insurer, we understand that there are two bills - one from the provider to the DTN/PPO and a second from the DTN/PPO to the insurer. For the CMS-1500 initiative, only the first bill (from the provider to the DTN/PPO) should be sent through the XML submission partner and transmitted to the Board. If there is a dispute related to the medical bill, the provider would file an HP-1.0 and attach a copy of the bill they sent to the DTN/PPO.

• If "other" is selected as an objection reason in Section C on the C-8.1B, is it acceptable to list "see notes on EOR"?

  Yes, you may enter "see notes on EOR" in the descriptive box for objection reason #12 other, but matching CARC/RARC codes should also be included.

• If the provider submits bills electronically, will the Board be able to see what's submitted to the Board versus what's submitted to the payer?

  Electronically submitted medical bills that are transmitted through an approved XML submission partner should be the identical bill delivered to both the payer and the Board (with the exception that the Board's version will include the payer's acknowledgement date as an addition). The Board will only be able to see the medical bills that have been submitted to them.

• What should a payer do when they receive a bill from a DMEPOS supplier if the supplier does not have or provide their required Medicaid Management Information System (MMIS) number?

  Although there is no Board authorization of DME suppliers, in order to be able to provide DME supplies/services to injured workers, a DME supplier will need to be licensed by the NYS Department of Health Medicaid Program within six months of the effective date of the Official New York State Workers' Compensation DME Fee Schedule. Out-of-state DME suppliers providing DME items for injured workers residing outside of NYS will be exempt from this requirement. Payers may reject bills from in-state providers/suppliers if they do not provide their MMIS number on the bill. Payers may use the Medicaid Enrolled Provider Lookup tool to determine if the DME provider/supplier is enrolled.

• When will the new C-8.1B and C-8.4 forms become mandatory?

  The new C-8.1B and C-8.4 forms were implemented July 1, 2022 and will become mandatory on September 19, 2022. At that point, the current versions of the forms will not be accepted, and no action will be taken by the Board should a payer continue to use them.

• If a payer is not submitting a C-8.1B or C-8.4 to raise legal or valuation issues relating to a medical provider's bill, does the Board still want to receive the EOB/EOR?

  The Board only requires EOBs/EORs associated with the filing of a C-8.1B or C-8.4. The Board does not require or want all other EOBs/EORs (at the time of adjudication). It is possible that an EOB/EOR may subsequently be necessary if a provider files an HP-1.0 disputing payment.

• Some objections on the C-8.1B or C-8.4 forms allow for one or more RARCs but the form doesn't necessarily have space for more than two. In these instances, may we expand the RARC spacing beyond the underlined spacing already provided on the form in order to accommodate as many RARCs as the payer chooses to utilize?

  Yes, in situations where multiple RARCs are needed, please separate each with a comma. Also, to the extent possible, the primary RARC should be identified by listing it first. At least one RARC on a C-8.1B or C-8.4 form must agree with the EOB/EOR sent to the provider.

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