Workers’ Comp & Ancillary Services

Guide

Orthopedic Workers’ Compensation Billing: Authorizations, Fee Schedules and Common Denials

Orthopedic Workers’ Compensation Billing: Authorizations, Fee Schedules and Common Denials

Orthopedic Workers’ Compensation Billing: Authorizations, Fee Schedules and Common Denials

How orthopedic practices bill workers’ comp in California, New York and Texas: authorizations, fee schedules, required reports and common denials.

How orthopedic practices bill workers’ comp in California, New York and Texas: authorizations, fee schedules, required reports and common denials.

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11 min read

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Sources cited: 37

Two construction workers in safety vests at a job site

Short answer

Workers’ compensation pays for work injuries under state law, not a health plan contract. The employer’s insurer pays from a state fee schedule, the injured worker generally owes no copay or deductible, and surgery and other costly care often needs approval first. Clean claims need the right claim number, an accepted body part, authorization and required reports.

Workers’ compensation pays for work injuries under state law, not a health plan contract. The employer’s insurer pays from a state fee schedule, the injured worker generally owes no copay or deductible, and surgery and other costly care often needs approval first. Clean claims need the right claim number, an accepted body part, authorization and required reports.

Key takeaways

  • Confirm the carrier, claim number and accepted body parts before the first visit; errors in all three cause common denials.

  • California, New York and Texas each set their own fee schedule, authorization process, treatment guidelines, required reports and billing deadline.

  • Billing deadlines differ by state: 95 days in Texas, 120 days in New York and 12 months in California from the date of service.

  • New York retired its C-4 physician report forms in 2022; bills now go electronically on the CMS-1500 with a medical narrative.

  • Don’t collect copays or deductibles on a work injury claim; all three states restrict billing the injured worker.

Humata Health, Inc.





Prior authorization request (PAR) in OnBoard, through the Medical Portal


Doctor’s First Report (Form 5021), PR-2 progress reports, PR-4 at permanent and stationary



Likely meets coverage, coding and payment rules




  1. Check network rules: California Medical Provider Network participation, Texas certified network status, and New York Board authorization for the treating provider.

  2. Before scheduling surgery, advanced imaging, injections, DME or extended therapy, check whether the state requires authorization and start the request early.

  3. Rette’s agents read the operative and clinical notes in the EHR your practice already uses and check documentation against NCD and LCD criteria before a request or claim goes out. Prior authorization, denials, appeals and workers’ compensation work sit in one prioritized queue, so WISeR requests, ADR deadlines and resubmissions are tracked alongside your other payer work.

Rette’s agents read the operative and clinical notes in the EHR your practice already uses, suggest codes, and validate claims against NCCI, NCD and LCD rules before submission. Prior authorization, denials, appeals and workers’ compensation work sit in one prioritized queue, so staff can see what needs attention first.

Orthopedic practices treat a steady stream of work injuries: fractures, rotator cuff and meniscus tears, back injuries, and the surgery and therapy that follow. Those claims don’t run on health plan rules. A state agency sets the fee schedule, decides what needs approval first, and requires its own reports, forms and deadlines.

This guide explains how workers’ comp billing differs from health insurance, compares three large systems (California, New York and Texas) using each state’s own rules, and walks through common orthopedic denials and intake steps. Rules and forms change often, so confirm edge cases with the state agency, the claims administrator or your compliance team.

How is workers’ comp different from billing a health plan?

  • State law sets the rules. Each state’s statute and agency regulations govern coverage, payment and disputes. Medicare policies apply only where a state adopts them, as Texas does for coding and payment policy on non-network professional claims.

  • The claim number comes from the employer’s carrier. The insurer, self-insured employer or third-party administrator assigns a claim number to each injury. New York also issues a Workers’ Compensation Board (WCB) case number, which belongs in field 9a of the CMS-1500 when known.

  • The worker has no cost-sharing to collect. California, New York and Texas all restrict providers from collecting from the injured worker (see the FAQ below).

  • Prices come from a state fee schedule, unless the state allows a network or contract rate.

  • Treatment guidelines drive approvals. California uses the Medical Treatment Utilization Schedule (MTUS), New York its Medical Treatment Guidelines (MTGs), and Texas the Official Disability Guidelines (ODG) for non-network claims. Utilization review applies those guidelines to treatment requests.

  • Reports are part of the claim. Each state requires initial, progress and work-status reporting, and missing reports stall payment.

  • MMI, impairment ratings and independent exams shape the case. Physicians decide when the worker has reached maximum medical improvement (MMI) and rate any permanent impairment.

  • Disputes go through state processes such as bill review, arbitration, independent review or liens, not a health plan’s appeal levels.

How do California, New York and Texas compare?

Topic

California

New York

Texas

Agency

Division of Workers’ Compensation (DWC)

Workers’ Compensation Board (WCB)

TDI Division of Workers’ Compensation (DWC)

Professional fee schedule

Official Medical Fee Schedule: RVUs adjusted by county GPCIs, times a California conversion factor

The Board’s own Medical Fee Schedule; a revised update was proposed in August 2026

Medicare RVUs and payment policies with DWC conversion factors ($72.07, or $90.48 for surgery in a facility, in 2026)

Treatment guidelines

MTUS, presumed correct

New York MTGs

ODG for non-network claims

Authorization

DWC Form RFA with supporting records; prospective decision within 5 business days

Prior authorization request (PAR) in OnBoard, through the Medical Portal

Preauthorization for listed services; carrier answers within 3 working days

Key reports

Doctor’s First Report (Form 5021), PR-2 progress reports, PR-4 at permanent and stationary

CMS-1500 plus medical narrative; Form C-4.3 for MMI and permanency

DWC-073 work status report; DWC-069 for MMI and impairment

Billing deadline

12 months from date of service

120 days from date of service

95 days from date of service

Fee disputes

Second bill review, then Independent Bill Review

Form HP-1.0 arbitration in OnBoard

Medical fee dispute resolution (DWC Form-060) within one year

California

Treatment requests go on the DWC Form RFA with documentation supporting medical necessity. Under the utilization review (UR) regulation, prospective decisions are due within 5 business days of a complete RFA, or 72 hours for expedited review. Outside expedited and concurrent review, a fax sent after 5:30 p.m. Pacific counts as received the next business day. The requesting physician must be told of the decision within 24 hours, with written notice within 2 business days for prospective review. If the reviewer asks for missing records and doesn’t get them within 14 days, the request is denied until they arrive.

The MTUS is presumed correct on the extent and scope of treatment. A physician who wants care that varies from it must rebut that presumption with a preponderance of scientific medical evidence, and conditions the MTUS doesn’t address follow other evidence-based guidelines. File the Doctor’s First Report of Occupational Injury or Illness within 5 working days of the first exam, then PR-2 reports when the condition or plan changes and at least every 45 days during ongoing treatment. Bills must include the itemization, copies of reports and any authorization, and must be submitted within 12 months of service for dates on or after January 1, 2017.

New York

New York replaced the C-4 family of physician reports (C-4, C-4.2, C-4AMR and related forms) with the CMS-1500 on July 1, 2022. The initial bill and narrative are due within 48 hours of first treatment, a follow-up 15 days after first treatment, and later reports after follow-up visits no more than 90 days apart. Every narrative must state work status, causal relationship and temporary impairment percentage. Since August 1, 2025, bills must go through a Board-approved electronic submission partner. Form C-4.3 remains in use as the narrative attached to MMI and permanency bills.

Treatment consistent with the MTGs doesn’t need prior approval, except listed special services such as knee arthroplasty, osteochondral autograft, autologous chondrocyte implantation, meniscal allograft, lumbar fusion and bone growth stimulators. MTG variances, special services, and non-MTG treatment over $1,000 require a PAR, submitted in OnBoard through the Board’s Medical Portal; these replaced the paper MG-2 and C-4AUTH forms. Providers generally must be Board-authorized before treating injured workers.

Texas

Texas doesn’t require most private employers to carry workers’ comp, so confirm coverage before treating. For non-network care, DWC applies Medicare’s RVUs, coding and payment policies, including correct coding (NCCI procedure-to-procedure) edits and modifiers, with Texas conversion factors. DWC’s quick estimate puts its 2026 factors at about 216% of the Medicare rate for most services and 271% for surgery in a facility. Certified network claims follow the network contract.

Non-network preauthorization covers listed services, including outpatient or ambulatory surgery, inpatient admissions, spinal surgery, DME over $500 per item, physical and occupational therapy (except the first six visits within two weeks of the injury or a preauthorized surgery), and treatment the ODG doesn’t recommend or address. Office visits don’t need it. After the first exam, and after any change in work status or substantial change in restrictions, the treating doctor gives the worker a DWC-073 at the visit and sends it to the carrier and employer within 2 working days. Bills go on the CMS-1500 within 95 days.

What happens at MMI, impairment rating and independent exams?

MMI is the point where the condition has stabilized. California’s “permanent and stationary” status means the same thing: well stabilized and unlikely to change substantially in the next year. Each state then has a rating and examination process:

  • California: the primary treating physician reports permanent and stationary findings within 20 days of the exam, describing impairment under the AMA Guides, 5th Edition (Form PR-4). Qualified and agreed medical evaluators handle medical-legal evaluations.

  • New York: the treating physician bills the MMI or permanency exam on the CMS-1500 with Form C-4.3 attached. Independent medical exam reports go on the IME-4 cover sheet, with copies due the same day to the Board, carrier, attending physician and worker.

  • Texas: designated doctors, requested through DWC, address questions such as MMI and impairment using the AMA Guides, 4th Edition, and report on the DWC-069 Report of Medical Evaluation. Reaching MMI doesn’t end treatment approvals; preauthorization decisions must still rest on medical necessity.

How are payment disputes and liens resolved?

California separates amount disputes from everything else. Request a second bill review within 90 days of the explanation of review; the claims administrator has 14 days to respond. If the amount is still disputed, file Independent Bill Review within 30 calendar days. Medical necessity disputes go to Independent Medical Review. Other disputes, such as denied liability, go to the Workers’ Compensation Appeals Board, where providers file liens electronically with a $150 fee. For services on or after July 1, 2013, a lien must be filed within 18 months of the service date.

New York requires payers to pay or object on Form C-8.1B within 45 days. If a bill stays unpaid without an open legal objection, file Form HP-1.0 in OnBoard for arbitration; paper HP-1.0 forms are no longer accepted.

Texas sends amount disputes to medical fee dispute resolution on DWC Form-060, filed within one year of service, with limited exceptions. Medical necessity denials go to reconsideration and then an independent review organization (Form LHL009, within 45 days of the reconsideration denial).

What are the common workers’ comp denials in orthopedics, and how do you prevent them?

Most of these trace back to intake and documentation rather than coding. The reason codes below are examples; payers choose their own. For denial patterns outside workers’ comp, see our guide to common orthopedic claim denials.

Denial

Example reason code

How to prevent it

No authorization

CARC 197 (authorization or precertification missing)

Check the state’s rules before scheduling; keep the approval number, dates, units and codes with the order and bill to match them

Wrong or missing claim number

CARC 16 (missing information or billing error)

Verify the claim number with the adjuster at intake; in New York, add the WCB case number in field 9a when known

Body part not accepted

CARC 219 (denied on extent-of-injury grounds)

Confirm accepted body parts before treating a new area; California UR can be deferred while liability for a body part is disputed

Missing reports

CARC 252 (attachment or documentation needed)

Send required reports with or before the bill: California itemization with reports, New York narrative, Texas DWC-073

Billed the health plan instead

CARC 19 from the health plan (work injury, so the comp carrier is liable)

Ask about work injury at check-in and flag the account before any claim goes out

Timely filing

CARC 29 (filing deadline passed)

Track 95 days in Texas, 120 days in New York and 12 months in California

Authorization records matter even after the fact. In a June 2026 Texas fee dispute over physical therapy, the carrier’s reductions included CARC 197, and DWC ordered no additional payment because the provider didn’t submit an authorization showing the approved dates and units.

What intake steps should your front desk follow?

  1. Ask every injury patient whether the injury happened at work, and flag the account before anything is billed to a health plan.

  2. Record the employer’s name and address, the date of injury, and the body parts and mechanism of injury in the patient’s words.

  3. Identify the carrier or third-party administrator and the claim number; in New York, also capture the WCB case number when one exists.

  4. In Texas, confirm the employer has coverage, since coverage is optional for most private employers.

  5. Confirm with the adjuster that the claim is open and which body parts are accepted; note the adjuster’s name, phone number and the date.

  6. Check network rules: California Medical Provider Network participation, Texas certified network status, and New York Board authorization for the treating provider.

  7. Don’t collect copays or deductibles; explain that the carrier pays.

  8. Before scheduling surgery, advanced imaging, injections, DME or extended therapy, check whether the state requires authorization and start the request early.

  9. Calendar report and billing deadlines: California’s Doctor’s First Report within 5 working days, New York’s initial narrative within 48 hours, and Texas’s DWC-073 to the carrier within 2 working days.

How Rette helps

Rette’s agents read the operative and clinical notes in the EHR your practice already uses, suggest codes, and validate claims against NCCI, NCD and LCD rules before submission. Prior authorization, denials, appeals and workers’ compensation work sit in one prioritized queue, so staff can see what needs attention first.

Frequently asked questions

Can we collect a copay from a patient with an open workers’ comp claim?

Generally no. California bars providers from collecting from a worker who has filed a claim while it is pending, unless the provider has written notice that the employer rejected liability and gives the worker a copy. New York bars providers from collecting any fee from a compensation claimant. Texas bars private claims against the worker unless the injury is adjudicated not compensable. Confirm the specifics with the carrier and your compliance team before billing a patient.

What if the carrier says the injury isn’t work-related?

Get the denial in writing and follow the state’s process before billing anyone else. In California, liability disputes go to the Workers’ Compensation Appeals Board, and a provider can’t collect from the worker on a pending claim without written notice of rejection. In Texas, a provider may pursue the worker only after the injury is adjudicated not compensable. Keep the denial and your records together so billing staff can redirect the claim quickly if allowed.

Do Medicare’s NCCI edits apply to workers’ comp claims?

It depends on the state. Texas’s professional fee guideline for non-network care applies Medicare payment policies, including correct coding edits and modifiers, with Texas conversion factors. California and New York publish their own fee schedules and billing rules, so check each state’s ground rules before assuming a Medicare edit or modifier policy applies. When in doubt, ask the claims administrator which edits its bill review uses.

How long do we have to submit a workers’ comp bill?

Texas requires bills within 95 days of the date of service, with limited statutory exceptions. New York requires bills within 120 days of the date care was rendered. California requires the request for payment within 12 months of the date of service for services on or after January 1, 2017, with good-cause exceptions, such as an injury first treated as non-occupational that is later found compensable.

Sources

  1. Cal. Code Regs. Tit. 8, § 9792.9.1 - Utilization Review Standards-Timeframe, Procedures and Notice - on or After January 1, 2013 — California DWC regulation, text via Cornell LII, last amended effective February 12, 2014

  2. Cal. Code Regs. Tit. 8, § 9785 - Reporting Duties of the Primary Treating Physician — California DWC regulation, text via Cornell LII

  3. Cal. Code Regs. Tit. 8, § 9789.12.2 - Calculation of the Maximum Reasonable Fee - Services Other than Anesthesia — California DWC regulation, text via Cornell LII

  4. Cal. Code Regs. Tit. 8, § 9792.21 - Medical Treatment Utilization Schedule — California DWC regulation, text via Cornell LII

  5. Cal. Code Regs. Tit. 8, § 9792.5.5 - Second Review of Medical Treatment Bill or Medical-Legal Bill — California DWC regulation, text via Cornell LII

  6. Cal. Code Regs. Tit. 8, § 9792.5.7 - Requesting Independent Bill Review — California DWC regulation, text via Cornell LII

  7. California Labor Code section 4603.2 (2025) — California Legislature, code text via Public.Law

  8. California Labor Code section 3751 (2025) — California Legislature, code text via Public.Law

  9. California Labor Code section 4903.05 (2025) — California Legislature, code text via Public.Law

  10. California Labor Code section 4903.5 (2025) — California Legislature, code text via Public.Law

  11. CMS-1500 Initiative Frequently Asked Questions — New York State Workers’ Compensation Board, accessed October 2026

  12. CMS-1500 Overview — New York State Workers’ Compensation Board, accessed October 2026

  13. CMS-1500 Important Tips and Reminders — New York State Workers’ Compensation Board, accessed October 2026

  14. PROVIDERS: Submitting bills through an electronic submission partner — New York State Workers’ Compensation Board, fact sheet v4, August 2025

  15. CMS-1500 Q&A for Health Care Providers — New York State Workers’ Compensation Board, 2022

  16. What Providers Need to Know — New York State Workers’ Compensation Board, accessed October 2026

  17. OnBoard: Health Care Providers — New York State Workers’ Compensation Board, accessed October 2026

  18. Medical Portal: Health Care Providers — New York State Workers’ Compensation Board, accessed October 2026

  19. WCB Medical Treatment Guidelines Frequently Asked Questions — New York State Workers’ Compensation Board, accessed October 2026

  20. Medical Fee Schedules — New York State Workers’ Compensation Board, accessed October 2026

  21. Proposed Amendments to Sections 329-1.3, 329-4.2, 333.2, 343.2, and 348.2 of Title 12 of the NYCRR (Medical Fee Schedules Update, Revised Proposal) — New York State Workers’ Compensation Board, August 21, 2026

  22. Medical Billing Disputes — New York State Workers’ Compensation Board, accessed October 2026

  23. Cover Sheet for Report of Independent Medical Examination (IME-4) — New York State Workers’ Compensation Board, form rev. 5-18

  24. New York Workers’ Compensation Law § 13-F, Payment of medical fees — New York State Senate, accessed October 2026

  25. Medical fee guideline conversion factors — Texas Department of Insurance, Division of Workers’ Compensation, updated April 10, 2026

  26. 2026 Professional and Workers’ Compensation Specific Exams Reimbursement Rates — Texas DWC, updated January 15, 2026

  27. Medical billing — Texas DWC, updated July 10, 2025

  28. Workers’ Comp Boot Camp: Preauthorization, Medical Necessity and Utilization Review — Texas DWC, accurate as of June 18, 2026

  29. 28 Tex. Admin. Code § 134.600 - Preauthorization, Concurrent Utilization Review, and Voluntary Certification of Health Care — Texas DWC rule, text via Cornell LII, amended effective December 28, 2023

  30. 28 Tex. Admin. Code § 133.20 - Medical Bill Submission by Health Care Provider — Texas DWC rule, text via Cornell LII, amended effective March 14, 2024

  31. 28 Tex. Admin. Code § 133.307 - Medical Fee Dispute Resolution — Texas DWC rule, text via Cornell LII, amended effective February 22, 2021

  32. Texas Workers’ Compensation Work Status Report (DWC Form-073) — Texas DWC, form rev. 09/19

  33. Workers’ compensation insurance coverage verification — Texas DWC, accessed October 2026

  34. Medical fee dispute resolution — Texas DWC, updated October 6, 2026

  35. Designated doctor program — Texas DWC, updated September 29, 2026

  36. Medical Fee Dispute Resolution Findings and Decision, M4-26-2514-01 — Texas DWC, June 3, 2026

  37. Claim Adjustment Reason Codes — X12, accessed October 2026

This guide is educational and is not legal, coding-compliance or billing advice. Payer rules change often, so confirm requirements with the payer before you bill. CPT® is a registered trademark of the American Medical Association; code descriptions here are Rette’s plain-language summaries.

See how Rette catches orthopedic denials before claims go out

See how Rette catches orthopedic denials before claims go out

See how Rette catches orthopedic denials before claims go out

Rette reads the operative note in the EHR you already use, suggests codes and checks claims against payer and NCCI rules before submission.