New York’s Workers’ Compensation Board (WCB) is cracking down on payers that refuse to reimburse providers for CPT 99080.

With electronic billing (e-billing) mandatory for all workers’ comp treatment, New York allows providers to offset e-billing costs by charging up to $1.00 per e-bill under CPT 99080. Unfortunately, some payers appear to have a habit of failing to reimburse providers for CPT 99080.

The WCB now instructs that, effective March 31, 2026, providers may submit a Request for Decision on Unpaid Medical Bill(s) (Form HP-1.0) when payers fail to reimburse for CPT 99080. The WCB may impose a $50 penalty on the payer for each HP-1 submitted by a provider.

We applaud the NY WCB for its forward-thinking efforts. The agency is using e-billing to both gather essential data necessary to improve the system and enforce payer compliance.

CPT 99080 for NY Workers’ Comp Billing

Effective August 1, 2025, New York providers treating injured workers must send bills to payers electronically through a WCB-approved Submission Partner. In addition to sending the e-bill to the payer, the Submission Partner must also send all e-bill data to the WCB in the required XML format.

To ease the financial costs of e-billing, the WCB allows providers to add CPT 99080 to each e-bill, charging the payer up to $1.00 so long as the amount accurately reflects the cost of submitting the bill electronically.

Note: For our New York clients, daisyBill technology automatically prompts providers with the option to add CPT 99080 with a $1.00 reimbursement amount to all e-bills.

Initially, the WCB instructed providers not to file an HP-1 when a payer fails to reimburse CPT 99080. Instead, the WCB told providers to gather multiple instances of improper CPT 99080 denials and report them in batches. However, on February 26, 2026, the WCB issued an announcement reversing that policy.

Starting on March 31, 2026, the WCB instructs (emphases ours):

“…in situations where the bill for services/treatment was paid or paid in part, but the offset code [aka CPT 99080] was not, providers may submit a Request for Decision on Unpaid Medical Bill(s) (Form HP-1.0). The Board may issue an administrative award on the payer for failure to pay the offset, including a $50 penalty for each instance of nonpayment for which a Form HP-1.0 is submitted…”

Further instructions for submitting HP-1s through the WBC’s OnBoard system are available here.

Providers, note that the WCB announcement instructs payers that if the only charge they object to on a provider’s bill is for CPT 99080, the payer must note that objection in the Explanation of Benefits. Payers may not submit an Insurer’s Refusal to Pay (Form C-8.4) or Notice of Objection to Payment (Form C-8.1B) solely because of CPT 99080 charges.

Per the WCB, the “only valid objection” to paying CPT 99080 is where:

• The amount the provider bills “exceeds the regulatorily permissible amount” (aka, is greater than $1 or exceeds the actual cost to submit the bill electronically)
• If CPT 99080 appears more than once on a single e-bill

Finally, the WCB reminds providers that e-billing for workers’ comp services has been mandatory since August 1, 2025, and that any provider who has not yet found an approved e-bill Submission Partner must do so “immediately.”

By mandating e-billing, the WCB is making it easier to gather data, track compliance, and empower providers to deliver care to injured workers more efficiently. daisyBill is here for New York providers who have questions about e-billing; use the pink chat icon in the bottom right of this screen, or email our team at info@daisybill.com.

daisyBill is a WCB-approved e-bill Submission Partner for New York workers’ comp providers. Click below to learn more:

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