When a California employer illegally neglects to insure against work-related injuries, that violation can leave injured workers without coverage. Enter the Uninsured Employers Benefits Trust Fund (UEBTF), a fund maintained by the state that pays for care and benefits when employers shirk their duty.

Unfortunately for California providers, UEBTF does not adhere to state payment regulations and laws that apply to other payers, including the requirements to:

• Accept electronic bills (e-bills)
• Pay timely
• Pay self-executing penalties and interest for untimely payments

In a recent incident, UEBTF failed to respond to a provider’s bills, and a daisyBill representative emailed UEBTF to investigate. After weeks of back-and-forth, UEBTF offered to pay two of the multiple outstanding bills at reimbursement rates significantly below those of the state fee schedule.

While UEBTF is a unique entity serving a unique role in the system, it has no defensible reason to be exempt from the most basic, important laws and regulations designed to protect providers and injured workers.

A warning to all California providers: Treating UEBTF injured workers is not worth the payment hassle. Do not burden your administrative staff with the all-but-impossible task of chasing down payment. Say no to UEBTF.

UEBTF: Playing by Its Own Rules

In February, daisyCollect snail-mailed a bill to UEBTF on behalf of one of our clients.

Mailing a bill might seem strange for an e-billing software company, especially in a state where the law requires all workers’ comp claims administrators to accept e-bills. However, both the section of the California Code of Regulations governing medical billing and the California Division of Workers’ Compensation’s Medical Billing and Payment Guide define a “claims administrator” as an insurer, self-insured employer, or Third-Party Administrator (TPA):

“...a self-administered insurer providing security for the payment of compensation required by Divisions 4 and 4.5 of the Labor Code, a self-administered self-insured employer, or a third-party administrator for a self-insured employer, insurer, legally uninsured employer, or joint powers authority.”

Technically, UEBTF is none of the above, operating in a legally ambiguous area where laws and regulations apparently don’t apply. As a result, UEBTF openly refuses to accept e-bills, even in the year 2026.

Accordingly, the daisyBill Claims Administrator Directory assigns both UEBTF’s Southern and Northern divisions an Electronic Data Interchange (EDI) grade of ‘F.’

In California, no provider should ever have to physically mail a bill. Yet, the state-run UEBTF burdens providers with snail-mailing original bills, as well as duplicate bills when the agency fails to respond.

UEBTF Ignores Bills, Tries to Give Itself Discounts

In July, daisyCollect emailed UEBTF about its failure to pay one of the provider’s bills (and the duplicate bill sent afterward).

In the email exchange, UEBTF asked for another copy of the bill, requested a “summary itemized bill with all the charges paid” despite never having paid the bill, and confirmed that UEBTF never sent an Explanation of Review.

During the email communications, daisyBill alerted UEBTF that it failed to pay a second bill from the same provider, for a total reimbursement amount due of $469.18 under the fee schedule. UEBTF responded by offering to pay $312.14 in total. This amount represented 92% of the fee schedule rate for one bill and 41% for the other, without citing any justification for the proposed discount.

Our representative made it clear to UEBTF, in no uncertain terms, that we will not accept sub-fee-schedule rates (at least absent a separate discount reimbursement agreement).

UEBTF Fails to Pay Eleven Bills

daisyCollect showed UEBTF nine other unpaid bills for the same patient’s treatment, for a total of 11 bills representing $2,556.27 in reimbursement owed at fee schedule rates.

UEBTF responded with a vague, noncommittal reply in which their representative claimed, “I did the review manually with the intent to expedite the payment for speedy resolution,” and directed us to contact the “assigned examiner” to proceed.

UEBTF may serve as a necessary backstop to ensure coverage for injured workers. However, that should not give this entity special privileges when it comes to paying providers correctly, on time, and without imposing the absurd (literal) paperwork and excessive delays that come with non-electronic billing.

For providers, treating workers covered under UEBTF simply isn’t worth the hassle. Our recommendation: just say NO.

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