New York's transition to mandatory electronic billing (e-billing) for workers' comp has introduced a code that every provider and biller in the state needs to understand: CPT 99080.

This article explains what CPT 99080 is, how it works in New York workers' comp billing, why payers have been denying it, and what providers can do about those denials starting March 31, 2026.

What Is CPT 99080 in New York Workers' Comp?

CPT 99080 typically covers special reports a physician prepares beyond standard medical records in connection with a workers' comp claim. In New York workers' comp, the Workers' Compensation Board (WCB) has repurposed the code for a different function entirely.

In New York workers' comp e-billing, CPT 99080 is an administrative cost-recovery code. Providers add it to each electronic CMS-1500 bill to charge the payer for the cost of submitting that bill through a WCB-approved XML Submission Partner. The maximum reimbursement is $1.00 per e-bill.

This is not a clinical code in this context. Providers and billers who encounter payer pushback on CPT 99080 should understand that its use here is explicitly authorized and required by the WCB.

Background: New York's Mandatory e-Billing System

The WCB mandated e-billing for New York workers' comp providers effective August 1, 2025. Under the mandate, providers must submit all workers' comp treatment bills electronically through a WCB-approved XML Submission Partner. Approved partners transmit the bill to the payer and send the full bill data to the WCB in XML format.

The WCB maintains the current list of approved XML Submission Partners at wcb.ny.gov. As of 2025, there are six approved partners. daisyBill is one of them.

Providers who submit paper bills after August 1, 2025 have no enforcement recourse if a payer refuses to pay. The WCB will not take action on paper bills submitted after the mandatory e-billing date.

How CPT 99080 Offsets E-Billing Costs

The WCB recognized that adopting e-billing technology carries a cost for providers. To offset that cost, the WCB repurposed CPT 99080 to allow providers to charge payers for the per-bill cost of electronic submission. The WCB authorized providers to begin using CPT 99080 on August 1, 2024, one year before e-billing became mandatory.

WCB Subject Number 046-1707 and subsequent WCB bulletins set out the rules for billing CPT 99080:

• CPT 99080 must appear on the same CMS-1500 form as the treatment services being billed. It cannot be submitted as a standalone bill.
• The charge must accurately reflect the provider's actual cost of submitting that individual bill electronically, up to a maximum of $1.00.
• CPT 99080 may appear only once per e-bill. Billing it more than once on the same form is a compliance error.

What Payers Are and Are Not Allowed to Do

The WCB has been clear about payer obligations. Payers must reimburse providers for CPT 99080 charges that comply with the above rules.

The only two valid grounds for a payer to deny a CPT 99080 charge are:

1. The amount billed exceeds $1.00 or exceeds the provider's actual submission cost.
2. CPT 99080 appears more than once on the same bill.

Payers may not file a Form C-8.4 (Insurer's Refusal to Pay) or Form C-8.1B (Notice of Objection) solely because of a CPT 99080 charge. When CPT 99080 is the payer's only objection, the payer must note that objection in the Explanation of Benefits, not through a C-8 form.

daisyData: Payers Denied CPT 99080 at High Rates Throughout 2025

Despite the WCB's clear directive, payers failed to reimburse CPT 99080 at alarming rates throughout 2025. daisyBill tracked CPT 99080 payment and denial rates across all e-bills submitted by our New York providers and shared that data with the WCB.

From January through July 2025, across approximately 37,000 e-bills, payers denied CPT 99080 on 64% of e-bills. Forty payers denied CPT 99080 on 100% of e-bills during that period.

From January through September 2025, across approximately 57,800 e-bills, the overall denial rate was 55%. The monthly denial rate fell from 89% in January to 40% in September, reflecting gradual improvement, but 40% non-compliance remains unacceptable. At $1.00 per violation, payers improperly withheld more than $27,000 from New York providers through September 2025.

The table below shows CPT 99080 denial rates for selected large payers for January through September 2025.

The WCB's Initial Guidance on Disputing 99080 Denials

When the WCB introduced CPT 99080, it instructed providers not to file Form HP-1.0 (Request for Decision on Unpaid Medical Bill) to dispute denials of the code. Instead, the WCB asked providers to gather multiple examples of improper denials and report them in batches directly to the WCB. The WCB committed to increasing communications with payers to clarify that CPT 99080 is a legitimate and required charge.

What Changed in March 2026: HP-1 Filings Now Permitted

On February 26, 2026, the WCB issued an announcement reversing its earlier guidance on disputing CPT 99080 denials. Effective March 31, 2026, providers may file a Form HP-1.0 for each instance where a payer fails to reimburse CPT 99080. The WCB announcement states:

"…in situations where the bill for services/treatment was paid or paid in part, but the offset code [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…"

The WCB noted in the same announcement that payers may not file C-8.4 or C-8.1B forms solely to object to CPT 99080 charges.

Instructions for submitting HP-1 forms through the WCB's OnBoard system are available at wcb.ny.gov/onboard/training-providers/hp-1/.

We applaud the WCB for taking decisive action to enforce CPT 99080 compliance. The HP-1 mechanism gives providers a formal, per-instance remedy and puts payers on notice that non-compliance carries direct financial consequences.

What Providers and Billers Should Do

Confirm You Are E-Billing Through an Approved Submission Partner

If you are still submitting paper bills for New York workers' comp, you must find a WCB-approved XML Submission Partner immediately. The WCB has instructed providers without an approved partner to do so without delay. The current list of approved partners is at wcb.ny.gov.

Add CPT 99080 to Every E-Bill

Add CPT 99080 to every CMS-1500 e-bill for NY workers' comp services. The amount should reflect your actual per-bill submission cost, up to $1.00, reported as a BR code. Add it once per form. daisyBill automatically prompts New York providers to add CPT 99080 at $1.00 to every e-bill.

Include the WCB Case Number in Field 9A

The WCB has described this as "VERY IMPORTANT." Every CMS-1500 must include the WCB Case Number in Field 9A. The WCB Case Number is the unique identifier assigned to each claim.

Track and Document Every CPT 99080 Denial

Keep a record of every instance where a payer fails to reimburse CPT 99080. Note the payer, the claim, the bill date, and the denial reason. daisyBill automatically documents CPT 99080 denials for our New York providers.

File HP-1.0 Forms for Unpaid CPT 99080 Charges

Effective March 31, 2026, file a Form HP-1.0 for each bill where treatment services were paid or partially paid but CPT 99080 was not reimbursed. Before filing, confirm:

• The underlying services on that bill were paid, at least in part.
• CPT 99080 appears only once on that bill.
• The amount billed for CPT 99080 does not exceed $1.00.
• The payer's denial does not fall within the two valid objection grounds described above.

Key Dates

Regulatory References

• WCB Subject Number 046-1707: CPT 99080 billing rules
• WCB Bulletin (August 2024): Payer reimbursement obligation for CPT 99080
• WCB Announcement (February 26, 2026): HP-1 authorization and $50 penalty provision
• Form HP-1.0: wcb.ny.gov/onboard/training-providers/hp-1/
• WCB Medical Portal: wcb.ny.gov/medicalportal/
• Approved XML Submission Partners: wcb.ny.gov/content/ebiz/XMLSubmissions/xmlSubmissions_vendorList.jsp

Don’t settle for a clearinghouse or group health RCM. daisyBill is a WCB-approved e-bill Submission Partner. Click below to learn more:

LEARN MORE: DAISYBILL