Hartford and P2P Fail CA e-Billing

May 3, 2023 9 min read

By: the daisyNews Team

California workers’ comp has lots of complicated laws, but one law is simple: claims administrators must accept electronic bills from providers.

Since claims administrators often lack the technology to accept e-bills directly from providers, they hire clearinghouses to both accept e-bills on the claims administrator’s behalf, and return the mandated electronic Explanations of Reviews (e-EORs) to providers.

However, California holds the claims administrator — not the clearinghouse — responsible for e-billing compliance. Thus, it is crucial for insurers, self-insured employers, and third-party administrators to choose their clearinghouse wisely.

Unfortunately, The Hartford, a workers’ comp insurer that acts as its own claims administrator, has made what we consider a poor choice of clearinghouse in P2P Link, LLC.

For almost an entire year, daisyBill has repeatedly contacted P2P in an attempt to establish a direct Electronic Data Interchange (EDI) connection with P2P, for the purpose of transmitting our clients’ e-bills directly to this clearinghouse vendor used by The Hartford.

As documented below, P2P has so far failed to implement the necessary EDI connection, resulting in daisyBill providers not receiving the mandated electronic Explanations of Review (e-EORs) from The Hartford.

Consequently, next week daisyBill will file over 17,000 Audit Complaints with the Division of Workers’ Compensation (DWC) reporting The Hartford’s EDI non-compliance.

Below we document the extraordinary obstacles The Hartford’s clearinghouse has erected, preventing the insurer’s acceptance of e-bills directly from providers. No provider or billing agent should have to work this hard to get an insurer to comply with California laws.

P2P & The Hartford: Failing CA Providers

The Hartford is the only major claims administrator known to daisyBill that uses P2P as its clearinghouse for California workers’ comp e-bills. Last year, after new management took the helm at P2P, we were (mistakenly) excited at the prospect of positive change.

Currently, daisyBill submits The Hartford’s e-bills to Jopari — an excellent clearinghouse, but not the clearinghouse tasked with accepting e-bills for The Hartford. Since Jopari is not The Hartford’s clearinghouse, daisyBill clients do not receive e-EORs in response to e-bills sent to The Hartford.

Furthermore, this indirect clearinghouse connection means that daisyBill cannot fully track EDI compliance for The Hartford (arguably a convenient side effect of The Hartford and P2P’s failure).

Accordingly, in May 2022, daisyBill reached out to P2P’s new management to inquire about establishing a direct EDI connection for The Hartford. As the painful exchange with P2P and The Hartford (documented below) demonstrates, both entities failed to comply with California law requiring claims administrators to accept e-bills directly from providers.

In fact, because of P2P’s failure thus far to establish the direct connection, daisyBill providers have not received over 17,000 e-EORs from The Hartford over the last 12 months.

The Hartford’s non-compliance is reflected in its daisyBill claims administrator data page, as shown below.

Unacceptable e-Billing Friction

At the end of this article is a detailed log of daisyBill’s outreach to both P2P and The Hartford, in our so-far-futile attempts to get P2P to establish the necessary connection and allow proper e-billing and payment.

To repeat: No provider should have to work this hard to get an insurer to comply with California laws.

In summary:

daisyBill first emailed P2P to establish the EDI connection on May 9, 2022. P2P representatives expressed enthusiasm.
When a contract was finally produced, it needed significant revisions; daisyBill asked for a P2P EDI implementation guide in the meantime, to get a head start before the contract was executed. P2P did not send the guide.
By November 29, 2022, daisyBill had met the agreed-upon contract terms with P2P and sent the final version of the contract to P2P. P2P reviewed the contract and approved the final terms.
daisyBill and P2P signed the contract in December 2022.
Over the course of the following three months, daisyBill reached out to P2P repeatedly for an update on implementation, but received no substantive response.
Beginning in April 2023, daisyBill reached out to The Hartford directly for updates on establishing the EDI connection. A Hartford representative indicated that P2P was “hoping” to complete the connection by the third quarter of 2023.
On April 18, 2023, a P2P representative apologized for the delay and made vague assurances that we should “hear something in the next few weeks” to “begin discussing next steps.”

The Hartford representative also offered the worst possible assurance re: California providers’ ability to e-bill the Hartford:

“In the meantime, CA providers are submitting WC bills thru P2P/Optum to [The Hartford] either directly or through a clearing house they partner with currently, such as Jopari, WC EDI, etc.”

Once more for the cheap seats: workers’ comp e-bills should not be submitted through any old clearinghouse. Per California EDI regulations, the correct electronic “address” for any e-bill is a combination of the exact clearinghouse used by the claims administrator and the Payer ID number assigned to that claims administrator.

At the end of April, P2P told daisyBill that the project was in P2P’s “review queue” but could not provide a specific timeline. In the same message, P2P referenced a “scare” regarding compliance with California regulations which “may hold up our connection progress.”

To be clear: this is no “scare.” Next week, daisyBill will fill 17,000+ Audit Complaints with the DWC, along with documentation of our failed efforts to directly connect with P2P. Furthermore, we will request the DWC perform a Targeted Audit, which may result in a $100 fine for each incidence of failure to adhere to California workers’ compensation regulations (that’s a potential $1,700,000 fine and rising, with each e-bill P2P fails to accept).

Fears regarding non-compliance are not causing the “holdup;” P2P’s holdups are causing non-compliance. California requires insurers to accept e-bills — without forcing providers through a digital gauntlet.

Date	Action
5/9/2022	daisyBill emailed p2plinksales@optum.com to inquire about establishing an EDI connection with P2P.
5/9/2022	P2P CSM replied: "That is excellent news! The first step will be getting a contract in place. Do you have a default you use or would you like to see P2P’s contract?"
5/9/2022	daisyBill asked P2P to send P2P's contract.
5/10/2022	daisyBill followed up with P2P regarding furnishing the contract.
5/11/2022	P2P replied: "Just wanted to do a quick follow up with you this morning so you know I am working on this. Our one legal rep who handles our P2P contracts was out of the office early this week. I’m following up with him again right now to see if we can get an updated contract over to you by the end of today."
5/12/2022	P2P provided the contract to daisyBill.
5/12/2022	daisyBill reviewed the contract and struck out the HIPAA requirement and $3 million cyber security insurance requirement.
5/16/2022	daisyBill followed up with P2P regarding the contract review.
5/18/2022	P2P replied: "Our legal team reconsidered the need for a BAA here. He believes that both P2P and DaisyBill would be Covered Entities under these circumstances, in which case a BAA would not be necessary regardless of the nature of the records being exchanged. Attached is the redline version highlighting the piece being removed and the new clean version."
5/18/2022	daisyBill reviewed the updated contract, made relevant changes, and returned the contract to P2P.
5/24/2022	daisyBill followed up with P2P regarding the contract review.
5/25/2022	P2P replied: "I just reached out to our legal team and the associate I’ve been working with is on PTO this week. I will connect with him on Tuesday to see if he had any issues with the changes and anticipate a completed agreement by next week."
5/25/2022	daisyBill asked P2P if they're able to send the EDI implementation guide before the agreement is signed.
6/1/2022	P2P did not reply to the EDI implementation guide request. daisyBill followed up with P2P to determine if the contract has been completed.
6/2/2022	P2P replied: "Our team just came back and noted the requirement that parties carry at least $3 million in cyber liability coverage was deleted. Is your objection to the amount or the actual coverage? Coverage is a standard requirement on our end."
6/10/2022	P2P replied: "Just wanted to follow up on this."
6/14/2022	daisyBill applied for cyber security insurance.
7/28/2022	daisyBill followed up with insurance broker.
8/10/2022	daisyBill followed up with insurance broker.
11/22/2022	daisyBill obtained cyber security insurance for $2 million.
11/29/2022	daisyBill updated the contract with the $2 million amendment and sent the contract to P2P.
12/6/2022	daisyBill followed up with P2P regarding the contract review.
12/6/2022	daisyBill received auto-reply email from P2P: "Thank you for your e-mail. I am currently out of the office returning on 12/07/2022. For any P2P inquiries, please reach out to OptumWC.SystemSupport@optum.com. For all other inquiries, please reach out to mbrclientservices@optum.com."
12/12/2022	P2P replied: "I’ve been working with my team to have this completed and they had a quick question on workflow; you would be planning on sending WC or auto related bills to be passed on electronically to their correct payers, correct?"
12/12/2022	daisyBill clarified that daisyBill will only send workers' comp bills.
12/15/2022	P2P replied: "Our team agreed to the changes. Once signed, our team will countersign and we can begin a project to connect our organizations."
12/15/2022	daisyBill sent the signed contract to P2P.
12/16/2022	P2P replied: "I’ve engaged our Agile product owners to begin mapping out a project plan. I imagine with year-end almost here and blackout periods beginning, we will probably pick this discussion up during early January sprint planning."
1/4/2023	daisyBill followed up with P2P regarding implementation next steps.
1/4/2023	P2P replied: "Our team is working on Sprint planning for the next three months this week so I should have an updated timeline and next steps for you by the end of this week."
1/17/2023	daisyBill followed up with P2P regarding implementation schedule.
1/23/2023	daisyBill followed up with P2P regarding implementation schedule.
1/30/2023	daisyBill followed up with P2P regarding implementation schedule.
1/30/2023	P2P replied: “My team is currently in sprint planning for Q2 2023 and I am pushing to have this connection developed during this time frame. I am working with the product owner and we just got the project out of backlog on Friday and into ranking so I’m hoping we have a rank assigned by this Thursday so I can see which sprint it will be pushed into. As soon as I hear, I will let you know so you can prepare resources on your side as well for implementation.“
3/6/2023	daisyBill followed up with P2P regarding implementation schedule.
3/13/2023	daisyBill followed up with P2P regarding implementation schedule.
3/22/2023	daisyBill followed up with P2P regarding implementation schedule.
3/27/2023	daisyBill followed up with P2P regarding implementation schedule.
3/27/2023	daisyBill received auto-reply email from P2P: "Thank you for your e-mail. I am currently out of the office, returning 04/10/2023. For any urgent inquiries for medical bill review or P2PLink services, please utilize the following contacts: Medical Bill Review: mbrclientservices@optum.com P2PLink: optumwc.systemsupport@optum.com Thanks!"
3/27/2023	daisyBill emailed optumwc.systemsupport@optum.com to inquire about the implementation schedule.
4/4/2023	daisyBill emailed The Hartford regarding delayed P2P EDI implementation.
4/4/2023	The Hartford WC Medical Bill Specialist directed daisyBill to The Harford Vendor Manager.
4/10/2023	daisyBill followed up with The Harford Vendor Manager regarding implementation schedule.
4/11/2023	The Harford Vendor Manager confirmed they reached out to P2P for an update.
4/14/2023	The Harford Vendor Manager provided an update from P2P: “the team is currently looking at moving this up to start being worked in the next few project sprints.”
4/17/2023	daisyBill asked The Harford Vendor Manager to provide a date when The Hartford will be EDI compliant.
4/18/2023	P2P replied to daisyBill: “Sorry for the delay, I have been out of the office traveling. Our team just picked up the implementation yesterday to begin reviewing requirements. I believe you should hear something in the next few weeks either from myself or another project manager to begin discussing next steps.”
4/25/2023	daisyBill followed up with The Hartford and P2P regarding implementation schedule.
4/25/2023	The Hartford Vendor Manager replied to daisyBill: “We were advised, the contract between Daisybill and P2P/Optum was executed in December 2022. Additionally, the manager at P2P/Optum who has been working with Daisybill indicated he talks to [daisyBill] almost weekly. At this time, P2P/Optum indicates they have been engaged in discussions to implement a connection line, hoping to have the implementation completed in Q3 2023. In the meantime, CA providers are submitting WC bills thru P2P/Optum to HIG either directly or through a clearing house they partner with currently, such as Jopari, WC EDI, etc.”
4/27/2023	P2P replied to daisyBill: “Our team currently has the project in their review queue and it will be worked over the next several sprints. I do not have a timeline available to me yet for testing. We also have another issue that has been brought to our legal team where a scare was sent to our partner about CA compliance. This may hold up our connection progress as our legal and compliance teams work through the concerns.”

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