Liberty Mutual’s ongoing failure to consistently adhere to California workers’ comp regulations should raise concerns for employers and healthcare providers.

Despite clear requirements from the California Division of Workers’ Compensation (CA DWC), Liberty Mutual routinely fails to send providers electronic Explanations of Review (e-EORs) as required.

Liberty Mutual’s non-compliance presents serious challenges for providers treating injured workers. California designed electronic billing (e-billing) rules to streamline administrative processes for insurers and providers. When insurers do not fully adhere to these requirements, it creates obstacles for providers—potentially discouraging them from treating injured workers.

Employers such as Costco, UPS, Home Depot, and IKEA rely on Liberty Mutual to facilitate care for their injured employees. But when insurers create administrative hurdles, securing treatment for injured workers becomes more difficult, ultimately impacting employers.

daisyBill has submitted a second formal Audit Complaint to the CA DWC detailing Liberty Mutual’s non-compliance with e-billing regulations.

Today’s article also identifies the employers who depend on Liberty Mutual for coverage. These employers should consider demanding Liberty Mutual adhere to sensible e-billing regulations rather than making it more difficult for providers to treat their employees.

Liberty Mutual: Fresh Non-Compliance in 2025

When a provider sends their workers’ comp bill electronically, California requires the claims administrators to electronically send the provider the e-EOR, which reports bill payment data.

These e-EORs update providers' systems automatically with payment details, just like Medicare and private insurance.

In 2024, Liberty Mutual repeatedly failed to comply with this requirement—and 2025 is off to a troubling start. In January alone, Liberty Mutual did not send e-EORs for 642 out of 5,856 e-bills, an 11% non-compliance rate.

Why should employers be concerned? Because Liberty Mutual’s failure creates unnecessary burdens for providers treating injured workers. Instead of an automatic update, providers must expend time and resources manually tracking payments and updating billing systems.

This inefficiency makes treating workers' compensation patients less viable than Medicare or private insurance. As a result, providers increasingly opt-out, reducing access to quality care and driving up costs as states raise reimbursement rates to keep providers in the system.

Ultimately, these higher reimbursements raise workers’ comp premiums, directly impacting employers’ bottom lines.

Liberty Mutual Violations Reflect Poorly on These Employers

Liberty Mutual made it more difficult, time-consuming, and expensive for providers to treat at least one employee of every company in the table below.

In particular, providers treating employees of large companies with higher workers’ comp medical bill volumes—like UPS, Costco, Universal Studios Theme Park, IKEA, Home Depot, the Los Angeles Times, and more—may waste considerable resources and lose revenue at a greater scale. Any provider acting in rational financial self-interest must consider the losses involved in treating these companies’ workers.

Regardless of size, if your company is on this list, Liberty Mutual effectively impedes care for your employees.

Following the table, see the full text of our Audit Complaint to the CA DWC detailing the latest violations.

Audit Complaint: Liberty Mutual’s 642 Violations in January 2025

To: [redacted]@dir.ca.gov

Subject: Liberty Mutual Insurance EDI Non-compliance: X12 835 Missing Count 642

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 642 electronic Explanations of Review (X12 835s) as mandated by California EDI regulations.

In January 2025, daisyBill providers sent Liberty Mutual 5,856 e-bills. Liberty Mutual failed to respond to 642 (11%) e-bills compliantly. In each instance, Liberty Mutual did not electronically send the provider an EOR (X12 835).

A provider's electronic receipt of an EOR (X12 835) is a critical component of electronic billing because when a claims administrator sends EORs electronically, the data contained in the 835 file automatically: 

1. Closes the payment loop for a workers’ comp e-bill and
2. Posts to the respective e-bill significantly reducing a provider's administrative burden of manually recording payment information to the e-bill.

On 2/4/2025, daisyBill sent the DWC an Audit Complaint reporting 7,369 instances of Liberty Mutual’s 835 non-compliance in 2024. The data below shows that Liberty Mutual’s non-compliance remains unabated in January 2025.

I’ve attached a CSV list containing a total of 642 e-bills providers submitted to Liberty Mutual, demonstrating the following:

Liberty Mutual Electronic EOR (X12 835) Missing - 642

For January 1, 2025 through January 31, 2025, this CSV lists 642 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

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