Liberty Mutual fails to uphold its obligations to workers’ compensation providers, making it even more challenging for providers to treat injured workers. All California employers should be alarmed by Liberty Mutual’s non-compliance.

When workers’ compensation insurers ignore even the most basic and sensible rules governing workers' compensation medical billing—rules that align with private insurance and Medicare practices—they impose unnecessary administrative burdens on medical providers who treat injured workers.

Liberty Mutual is driving up workers’ comp administrative costs for providers by its refusal to follow basic California payment regulations. In 2024 alone, the insurer failed to send over 7,000 required electronic Explanations of Review (e-EORs) to providers, forcing them into costly manual payment processing.

When providers face mounting administrative burdens due to insurer non-compliance, fewer agree to treat injured workers, leaving employers with limited provider options. As provider participation drops, one route for states to increase participation is to raise workers’ compensation fee schedules to entice providers to treat injured workers, increasing costs for all employers.

This week, daisyBill filed an Audit Complaint with the California Division of Workers’ Compensation (CA DWC), reporting 7,369 Liberty Mutual e-EOR violations. The CA DWC must act now to enforce e-billing regulations and protect providers, injured workers, and employers.

It’s indisputable that e-billing improves efficiency and fairness in workers’ compensation, benefiting payers, providers, injured workers, and their employers. However, for e-billing to function as intended, claims administrators must stop abusing the system and fulfill their legal obligations.

Liberty Mutual: Consistent Non-Compliance

As daisyData from e-bills our provider clients sent to Liberty Mutual reveals, the insurer failed to send providers e-EORs for between 10% and 16% of the e-bills sent in 2024. Over the year, this non-compliance affected 7,369 e-bills.

For every missing e-EOR, Liberty Mutual either failed to issue payment or forced providers to waste valuable resources manually inputting payment data. This unnecessary, additional administrative burden discourages providers from treating injured workers.

Liberty Mutual’s Silence in Response to Inquiries

When daisyBill detects a pattern of non-compliance, our agents first contact the claims administrator and/or the clearinghouse the claims administrator hires to accept and respond to e-bills on their behalf.

Below is a log of daisyBill’s attempts to reach Liberty Mutual and alert them to the problem—all of which Liberty Mutual met with silence. In all, daisyBill contacted 38 Liberty Mutual representatives and Liberty Mutual’s clearinghouse, Jopari.

According to the CA DWC Electronic Medical Billing and Payment Companion Guide, claims administrators are always legally responsible for e-billing compliance, regardless of the clearinghouse involved.

This week, daisyBill reported the violations we outlined above directly to the CA DWC Legal Unit, per instructions from CA DWC representatives. We urge the CA DWC to act appropriately and demonstrate its commitment to California employers and injured workers by insisting on payer compliance.

e-EORs: Mission-Critical for Workers’ Comp Revenue Management

California requires claims administrators to respond to e-bills with e-EORs for one critical reason: failing to send e-EORs undermines the entire purpose of e-billing.

When claims administrators comply with the rules, e-EORs automatically post payment details directly to the provider’s e-billing system, allowing providers and their staff to:

• Monitor for timely and accurate payment
• Maintain detailed, actionable analytics
• Take necessary steps, such as appealing improper denials

Without e-EORs, providers are forced back into a 20th-century nightmare—manually entering payment data, tracking missing payments, and wasting precious resources on administrative drudgery.

This failure by claims administrators is more than just an inconvenience; it’s a violation that increases provider costs to treat injured workers, discourages providers from treating injured workers, and ultimately increases California employers’ workers’ comp costs.

Audit Complaint:

To: [redacted]@dir.ca.gov

Subject: Liberty Mutual Insurance EDI Non-compliance: X12 835 Missing Count 7,369

Hello [Redacted],

Per correspondence with [redacted] exchanged on January 23, 2024, the Audit Unit has no authority over X12 835 EDI non-compliance. [Redacted] advised that the DWC Legal Unit handles these matters.

Below is an Audit Complaint reporting credible data that Liberty Mutual Insurance failed to send 7,369 electronic EORs (X12 835) as mandated by California EDI regulations.

This Audit Complaint data is aggregated from 7,369 workers’ comp e-bills submitted to Liberty Mutual by daisyBill providers from January 1, 2024 through December 31, 2024.

A provider's receipt of an electronic EOR (X12 835) is a critical component of electronic billing for the following three reasons:

1. The electronic EOR closes the payment loop for a workers’ comp e-bill and
2. Automatically posts to the respective e-bill, thereby significantly reducing a provider's administrative burden of manually recording payment information to the respective e-bill and
3. Allows the gathering of essential payment data about the claims administrator hidden in the paper EORs mailed to individual providers.

To procure e-EORs from Liberty Mutual for our clients, daisyBill contacted 38 Liberty Mutual representatives and the clearinghouse vendor, Jopari, with data demonstrating Liberty Mutual’s non-compliance. No one from Liberty Mutual responded to daisyBill’s inquiry.

On 1/21/2025, I emailed Liberty Mutual Director Regional Operations Manager [Redacted] about this EDI non-compliance. I included data demonstrating the consistent electronic EOR non-compliance for e-bills transmitted to Liberty Mutual in 2024. Liberty Mutual failed to reply or provide a resolution.

On 1/24/2025, I emailed 37 additional Liberty Mutual representatives with the same EDI non-compliance data. These Liberty Mutual representatives also failed to reply or provide a resolution.

On 1/29/2025, a daisyBill representative emailed Jopari to report Liberty Mutual’s EDI non-compliance and failure to respond to daisyBill emails.

On 1/30/2025, Jopari replied to daisyBill that they alerted the Liberty Mutual Account Manager.

The table below lists the e-bill and electronic EORs (X12 835) data gathered for Liberty Mutual, showing Liberty Mutual’s consistent electronic EOR non-compliance in 2024.

I’ve attached a CSV list containing a total of 7,369 e-bills providers submitted to Liberty Mutual, demonstrating the following:

Liberty Mutual Electronic EOR (X12 835) Missing - 7,369

For January 1, 2024 through December 31, 2024, this CSV lists 7,369 e-bills daisyBill providers submitted where Liberty Mutual failed to return a mandated electronic EOR to the provider in response to the e-bill. The attached CSV list includes the following columns:

• Column L: [Bill] Transmission Date
• Column W: EOR (835) Compliance Due Date
• Column X: EOR (835) Receipt Date - This column is BLANK because Liberty Mutual failed to send the provider an electronic EOR (835).
• Column AO: Patient Name
• Column AP: Claim Number

 daisyBill tracks payment and compliance—so your staff knows exactly what to do next. Book a quick call to learn how easy workers’ comp billing can be.

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