New York’s transition to mandatory electronic billing (e-billing) is facing its first snag. State regulators must decisively address this problem now.
While New York providers are complying with e-billing requirements, far too many payers are violating a state requirement to help offset the cost of e-billing for practices.
Since August of 2024, the Workers’ Compensation Board (WCB) has required payers to reimburse providers for the cost of electronic submission (up to $1) when an e-bill lists CPT 99080.
Yet, daisyData show that from January through September of 2025, payers in our systems denied payment for CPT 99080 on 55% of the e-bills our providers submitted.
Individually, dozens of payers denied payment for CPT 99080 more than 50% of the time. That includes the state’s largest workers’ comp carrier, the New York State Insurance Fund (NYSIF), which refused to pay for CPT 99080 charges on 52% of e-bills.
For providers, failure to bill electronically has automatic consequences: The payer can ignore the bill (the WCB will not take action to enforce payment of paper bills). For payers, we have yet to see the consequence for flagrantly and repeatedly failing to pay for CPT 99080.
Below, see our 2025 data on CPT 99080, which we have shared with the WCB per the agency’s instructions to report non-payment for this code.
New York faces a choice between establishing a culture of payer compliance or tacitly permitting provider abuse. We urge the WCB to take action and demonstrate that compliance goes both ways.
New York mandated workers’ comp e-billing to make it easier for practices to treat injured workers, help improve access to care, and collect critical, comprehensive claim data.
The results so far have been fantastic. New York providers who comply with e-billing requirements through one of six WCB-approved e-billing partners see faster payments, less administrative hassle, verified bill delivery, and easier overall revenue management.
To ease the financial cost of complying with the mandate, the WCB repurposed CPT 99080, allowing providers to bill the payer up to $1 for each e-bill. The agency has been crystal clear in instructing that payers must reimburse for CPT 99080.
Unfortunately, the data indicate that many payers are not adhering to WCB instructions.
From January 1 to September 30, 2025, the payers in our system collectively paid CPT 99080 45% of the time, resulting in a non-compliance rate of 55%.
The only positive trend is that non-payment has, for the most part, steadily decreased over the course of the year, from a high of 89% in January to a low of 40% in September. That acknowledged, 40% is still entirely unacceptable.
At $1 per e-bill, payers have collectively withheld $27,291 from New York providers this year.
NY e-Bill Submission Month |
Count of e-Bills (With CPT 99080 Charge) |
Processed Bill Count |
No Response to e-Bill Count |
No Response % |
CPT 99080 Paid Count |
CPT 99080 Paid % |
CPT 99080 Denied Count |
CPT 99080 Denied % |
Jan 2025 |
334 |
260 |
74 |
22% |
29 |
11% |
231 |
89% |
Feb 2025 |
1,976 |
1,663 |
313 |
16% |
280 |
17% |
1,383 |
83% |
Mar 2025 |
2,718 |
2,276 |
442 |
16% |
327 |
14% |
1,949 |
86% |
Apr 2025 |
8,790 |
7,103 |
1,687 |
19% |
1,421 |
20% |
5,682 |
80% |
May 2025 |
7,421 |
6,633 |
788 |
11% |
3,235 |
49% |
3,398 |
51% |
Jun 2025 |
6,724 |
6,144 |
580 |
9% |
2,889 |
47% |
3,255 |
53% |
Jul 2025 |
9,044 |
7,600 |
1,444 |
16% |
3,343 |
44% |
4,257 |
56% |
Aug 2025 |
9,730 |
8,072 |
1,658 |
17% |
4,677 |
58% |
3,395 |
42% |
Sep 2025 |
11,076 |
9,457 |
1,619 |
15% |
5,716 |
60% |
3,741 |
40% |
Totals |
57,813 |
49,208 |
8,605 |
15% |
21,917 |
45% |
27,291 |
55% |
The table below lists all New York payers in daisyBill’s systems, with each payer’s CPT 99080 compliance data for January through September 2025. Most disturbingly:
These are astonishing levels of non-compliance for some of the most consequential payers in the state. Moreover, dozens of payers, large and small, have non-compliance rates of 50% or higher.
The WCB instructed providers not to file Requests for Decision on Unpaid Medical Bill(s) (Form HP-1.0) to dispute 99080 denials; instead, the agency asked providers to track and report repeated violations by specific payers.
Accordingly, daisyBill is sharing data on CPT 99080 non-compliance with the WCB.
In this early stage of New York workers’ comp’s e-billing era, the state must take action to correct clear patterns of non-compliance. If payers become accustomed to a lack of meaningful consequences, the long-term results may completely undermine the state’s efforts to improve the system (just ask California providers).
Claims Administrator |
e-Bill Count (Includes 99080 Charge) |
Processed Bill Count |
No Response Count |
No Response % |
CPT 99080 Paid Count |
CPT 99080 Paid % |
CPT 99080 Denial Count |
CPT 99080 Denial % |
New York State Insurance Fund |
25,218 |
22,144 |
3,074 |
12% |
10,647 |
48% |
11,497 |
52% |
Sedgwick Claims Management Services, Inc. |
5,157 |
4,653 |
504 |
10% |
2,191 |
47% |
2,462 |
53% |
Gallagher Bassett Services Inc. |
2,392 |
2,362 |
30 |
1% |
573 |
24% |
1,789 |
76% |
The Black Car Fund |
2,333 |
2,321 |
12 |
1% |
1,391 |
60% |
930 |
40% |
New York City Law Department |
2,174 |
648 |
1,526 |
70% |
317 |
49% |
331 |
51% |
CorVel |
1,902 |
1,730 |
172 |
9% |
912 |
53% |
818 |
47% |
Travelers |
1,755 |
1,749 |
6 |
0% |
473 |
27% |
1,276 |
73% |
PMA Companies |
1,263 |
1,250 |
13 |
1% |
635 |
51% |
615 |
49% |
The Hartford |
1,147 |
1,101 |
46 |
4% |
610 |
55% |
491 |
45% |
Liberty Mutual Insurance |
1,046 |
1,033 |
13 |
1% |
334 |
32% |
699 |
68% |
ESIS, Inc. |
976 |
922 |
54 |
6% |
210 |
23% |
712 |
77% |
AmTrust North America, Inc. |
971 |
928 |
43 |
4% |
306 |
33% |
622 |
67% |
Zurich Insurance North America |
804 |
788 |
16 |
2% |
269 |
34% |
519 |
66% |
Chubb Group of Insurance Companies |
721 |
679 |
42 |
6% |
581 |
86% |
98 |
14% |
NCA Comp, Inc. |
654 |
632 |
22 |
3% |
182 |
29% |
450 |
71% |
Broadspire Services, Inc. |
611 |
584 |
27 |
4% |
247 |
42% |
337 |
58% |
The Risk Management Planning Group, Inc. |
558 |
99 |
459 |
82% |
44 |
44% |
55 |
56% |
Helmsman Management Services LLC |
539 |
526 |
13 |
2% |
130 |
25% |
396 |
75% |
Triad Group |
476 |
273 |
203 |
43% |
36 |
13% |
237 |
87% |
SAFE LLC |
395 |
371 |
24 |
6% |
296 |
80% |
75 |
20% |
New York City Police Department (NY) |
385 |
0 |
385 |
100% |
0 |
0% |
0 |
0% |
Wright Risk Management Company, LLC |
345 |
82 |
263 |
76% |
66 |
80% |
16 |
20% |
Hereford Insurance Company |
322 |
180 |
142 |
44% |
4 |
2% |
176 |
98% |
Cannon Cochran Management Services, Inc. |
285 |
261 |
24 |
8% |
85 |
33% |
176 |
67% |
National Liability and Fire Insurance Company |
279 |
265 |
14 |
5% |
35 |
13% |
230 |
87% |
Oriska Insurance |
273 |
2 |
271 |
99% |
0 |
0% |
2 |
100% |
Maine Employers Mutual Indemnity Company |
245 |
240 |
5 |
2% |
134 |
56% |
106 |
44% |
Next Level Administrators |
243 |
234 |
9 |
4% |
17 |
7% |
217 |
93% |
Guard Insurance Group |
241 |
229 |
12 |
5% |
75 |
33% |
154 |
67% |
FCS Administrators, Inc. |
214 |
208 |
6 |
3% |
135 |
65% |
73 |
35% |
Benetech, Inc. |
200 |
192 |
8 |
4% |
119 |
62% |
73 |
38% |
Crum & Forster |
193 |
192 |
1 |
1% |
102 |
53% |
90 |
47% |
None |
182 |
16 |
166 |
91% |
3 |
19% |
13 |
81% |
New Jersey Manufacturer's Insurance Group |
166 |
163 |
3 |
2% |
100 |
61% |
63 |
39% |
Marriott Claims Service Corp |
134 |
102 |
32 |
24% |
61 |
60% |
41 |
40% |
CNA Insurance |
103 |
73 |
30 |
29% |
44 |
60% |
29 |
40% |
Utica Mutual Insurance Co |
100 |
89 |
11 |
11% |
28 |
31% |
61 |
69% |
biBERK |
96 |
63 |
33 |
34% |
17 |
27% |
46 |
73% |
Employers Compensation Insurance Company |
90 |
78 |
12 |
13% |
29 |
37% |
49 |
63% |
Sentry Insurance |
90 |
90 |
0 |
0% |
59 |
66% |
31 |
34% |
Berkshire Hathaway Homestate Companies |
88 |
70 |
18 |
20% |
40 |
57% |
30 |
43% |
Erie Insurance Group |
86 |
75 |
11 |
13% |
19 |
25% |
56 |
75% |
Selective Insurance |
83 |
81 |
2 |
2% |
11 |
14% |
70 |
86% |
FutureComp |
79 |
8 |
71 |
90% |
2 |
25% |
6 |
75% |
Retail Business Services, LLC |
77 |
75 |
2 |
3% |
46 |
61% |
29 |
39% |
ARGO - Argonaut Insurance Company |
75 |
75 |
0 |
0% |
10 |
13% |
65 |
87% |
Applied Underwriters |
72 |
54 |
18 |
25% |
29 |
54% |
25 |
46% |
GCG Risk Management, Inc. |
70 |
61 |
9 |
13% |
25 |
41% |
36 |
59% |
Utica National Insurance Co of Texas |
64 |
50 |
14 |
22% |
15 |
30% |
35 |
70% |
MSA Careguard |
64 |
0 |
64 |
100% |
0 |
0% |
0 |
0% |
Tristar Risk Management |
54 |
38 |
16 |
30% |
28 |
74% |
10 |
26% |
National Casualty Company |
52 |
52 |
0 |
0% |
1 |
2% |
51 |
98% |
Oryx Insurance Brokerage, Inc. |
46 |
3 |
43 |
93% |
0 |
0% |
3 |
100% |
Berkley Environmental |
44 |
12 |
32 |
73% |
6 |
50% |
6 |
50% |
Cottingham & Butler Claims Services, Inc. |
44 |
44 |
0 |
0% |
37 |
84% |
7 |
16% |
Carisk Imaging Network |
40 |
8 |
32 |
80% |
1 |
13% |
7 |
88% |
Strategic Comp |
40 |
27 |
13 |
33% |
12 |
44% |
15 |
56% |
Suffolk County Risk Management (NY) |
37 |
36 |
1 |
3% |
1 |
3% |
35 |
97% |
Wegmans Food Markets, Inc. |
34 |
34 |
0 |
0% |
11 |
32% |
23 |
68% |
Constitution State Services LLC |
25 |
25 |
0 |
0% |
4 |
16% |
21 |
84% |
New York City Fire Department (NY) |
24 |
8 |
16 |
67% |
4 |
50% |
4 |
50% |
Dollar General |
24 |
23 |
1 |
4% |
6 |
26% |
17 |
74% |
Administrative Claim Service |
23 |
2 |
21 |
91% |
0 |
0% |
2 |
100% |
Protective Insurance |
23 |
23 |
0 |
0% |
17 |
74% |
6 |
26% |
Charles Taylor, TPA |
22 |
22 |
0 |
0% |
8 |
36% |
14 |
64% |
Hanover Insurance Company |
22 |
17 |
5 |
23% |
14 |
82% |
3 |
18% |
Acadia Insurance |
21 |
6 |
15 |
71% |
0 |
0% |
6 |
100% |
CareWorks Network |
21 |
17 |
4 |
19% |
0 |
0% |
17 |
100% |
Church Mutual Insurance Company |
18 |
18 |
0 |
0% |
4 |
22% |
14 |
78% |
Northeast Shared Services |
17 |
0 |
17 |
100% |
0 |
0% |
0 |
0% |
Network Adjusters, Inc |
16 |
7 |
9 |
56% |
1 |
14% |
6 |
86% |
Markel First Comp Insurance |
15 |
9 |
6 |
40% |
1 |
11% |
8 |
89% |
OccuSure Claims Services |
15 |
0 |
15 |
100% |
0 |
0% |
0 |
0% |
Tokio Marine Management, Inc. |
15 |
14 |
1 |
7% |
1 |
7% |
13 |
93% |
The Cincinnati Insurance Company |
14 |
11 |
3 |
21% |
0 |
0% |
11 |
100% |
GuideOne Insurance |
14 |
14 |
0 |
0% |
6 |
43% |
8 |
57% |
ProSight Specialty Insurance |
14 |
9 |
5 |
36% |
9 |
100% |
0 |
0% |
Federated Services Insurance Company |
13 |
13 |
0 |
0% |
3 |
23% |
10 |
77% |
Ryder Services Corp |
12 |
12 |
0 |
0% |
7 |
58% |
5 |
42% |
Madison Oneida Herkimer Work Comp Consortium |
12 |
0 |
12 |
100% |
0 |
0% |
0 |
0% |
Insurance Company of the West |
11 |
11 |
0 |
0% |
0 |
0% |
11 |
100% |
Vanliner Insurance Company |
11 |
4 |
7 |
64% |
0 |
0% |
4 |
100% |
Greater New York Mutual Insurance Company |
10 |
9 |
1 |
10% |
7 |
78% |
2 |
22% |
Golub Corporation |
10 |
2 |
8 |
80% |
0 |
0% |
2 |
100% |
The Zenith |
10 |
10 |
0 |
0% |
7 |
70% |
3 |
30% |
Transit General Insurance Company |
10 |
0 |
10 |
100% |
0 |
0% |
0 |
0% |
Merchants Insurance Group |
10 |
5 |
5 |
50% |
1 |
20% |
4 |
80% |
Core Specialty |
10 |
0 |
10 |
100% |
0 |
0% |
0 |
0% |
SafeCo Insurance |
10 |
10 |
0 |
0% |
0 |
0% |
10 |
100% |
Highview National Insurance Company |
9 |
0 |
9 |
100% |
0 |
0% |
0 |
0% |
Chesterfield Services |
9 |
0 |
9 |
100% |
0 |
0% |
0 |
0% |
A.G. Risk Management Inc. |
8 |
5 |
3 |
38% |
1 |
20% |
4 |
80% |
Phoenix Processor LP |
8 |
0 |
8 |
100% |
0 |
0% |
0 |
0% |
North American Risk Services |
8 |
8 |
0 |
0% |
1 |
13% |
7 |
88% |
National Interstate Insurance |
8 |
1 |
7 |
88% |
0 |
0% |
1 |
100% |
Rochester-Genesee Regional Transportation Authority (NY) |
7 |
0 |
7 |
100% |
0 |
0% |
0 |
0% |
Emerald Claims Management |
7 |
1 |
6 |
86% |
0 |
0% |
1 |
100% |
The Central Insurance Companies |
7 |
0 |
7 |
100% |
0 |
0% |
0 |
0% |
Creative Risk Solutions |
7 |
7 |
0 |
0% |
2 |
29% |
5 |
71% |
Michigan Millers Insurance |
7 |
1 |
6 |
86% |
0 |
0% |
1 |
100% |
Department of Labor |
7 |
7 |
0 |
0% |
4 |
57% |
3 |
43% |
Republic Franklin Insurance |
6 |
5 |
1 |
17% |
1 |
20% |
4 |
80% |
Glacier Bay TPA, LLC |
6 |
0 |
6 |
100% |
0 |
0% |
0 |
0% |
W.J. Cox Associates, Inc. |
6 |
3 |
3 |
50% |
3 |
100% |
0 |
0% |
Omaha National Group |
5 |
3 |
2 |
40% |
1 |
33% |
2 |
67% |
Fire Districts of New York Mutual Insurance Company |
5 |
4 |
1 |
20% |
3 |
75% |
1 |
25% |
Paradigm Management Services Network |
4 |
3 |
1 |
25% |
0 |
0% |
3 |
100% |
Blue Star Claims Management |
4 |
1 |
3 |
75% |
0 |
0% |
1 |
100% |
Nationwide Insurance Companies |
4 |
4 |
0 |
0% |
1 |
25% |
3 |
75% |
Tribal First |
4 |
0 |
4 |
100% |
0 |
0% |
0 |
0% |
World Trade Center Health Program |
4 |
0 |
4 |
100% |
0 |
0% |
0 |
0% |
Claimsake |
4 |
1 |
3 |
75% |
0 |
0% |
1 |
100% |
Packard Claims Administration |
4 |
1 |
3 |
75% |
0 |
0% |
1 |
100% |
Ford Motors Workers' Compensation |
4 |
4 |
0 |
0% |
0 |
0% |
4 |
100% |
Allianz |
3 |
3 |
0 |
0% |
1 |
33% |
2 |
67% |
Optum Network |
3 |
3 |
0 |
0% |
0 |
0% |
3 |
100% |
Electrical Employers Self Insurance Safety Plan |
3 |
0 |
3 |
100% |
0 |
0% |
0 |
0% |
Creative Comp Solutions Network |
3 |
0 |
3 |
100% |
0 |
0% |
0 |
0% |
Claims Service Bureau of New York |
3 |
1 |
2 |
67% |
0 |
0% |
1 |
100% |
OneCall Care Management Network |
3 |
2 |
1 |
33% |
0 |
0% |
2 |
100% |
United Heartland |
2 |
1 |
1 |
50% |
0 |
0% |
1 |
100% |
Innovative Claims Strategies, LLC |
2 |
0 |
2 |
100% |
0 |
0% |
0 |
0% |
Berkley Net Underwriters, LLC |
2 |
0 |
2 |
100% |
0 |
0% |
0 |
0% |
Transportation Claims, Inc. |
2 |
0 |
2 |
100% |
0 |
0% |
0 |
0% |
Applied Risk Solutions LLC |
2 |
0 |
2 |
100% |
0 |
0% |
0 |
0% |
Alaska National Insurance |
2 |
1 |
1 |
50% |
0 |
0% |
1 |
100% |
Coventry DME Plus Network |
2 |
2 |
0 |
0% |
0 |
0% |
2 |
100% |
Warren County (NY) |
2 |
0 |
2 |
100% |
0 |
0% |
0 |
0% |
Nordstrom Workers' Compensation |
2 |
2 |
0 |
0% |
0 |
0% |
2 |
100% |
Apricus Network |
1 |
1 |
0 |
0% |
0 |
0% |
1 |
100% |
Fairly Group |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
PRN Solutions Network |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
City of Mount Vernon Police Department (NY) |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
Great Divide Insurance |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
American Equity Underwriters |
1 |
1 |
0 |
0% |
1 |
100% |
0 |
0% |
MTI America Network |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
Sage Adjusting, LLC |
1 |
1 |
0 |
0% |
1 |
100% |
0 |
0% |
Brentwood Services Administrators, Inc. |
1 |
1 |
0 |
0% |
0 |
0% |
1 |
100% |
Normandy Insurance |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
AmeriTrust Group, Inc. |
1 |
1 |
0 |
0% |
0 |
0% |
1 |
100% |
Lawley Insurance |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
EMC Insurance Companies |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
Service Insurance Companies |
1 |
1 |
0 |
0% |
1 |
100% |
0 |
0% |
Monroe 2-Orleans BOCES (NY) |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
Key Risk Management Services LLC |
1 |
0 |
1 |
100% |
0 |
0% |
0 |
0% |
Totals |
57,813 |
49,208 |
8,605 |
15% |
21,917 |
45% |
27,291 |
55% |
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