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Frequently Asked Questions


  1. If I have a question on the CMS-1500 initiative, how can I get more information? Current news, FAQs, technical requirements and other resources can be found on the CMS-1500 Initiative section on the Board's website. If you have additional questions, please send an email to Questions posed to the dedicated mailbox will be promptly acknowledged. Responses will be posted to the FAQ section of the website regularly for the benefit of all stakeholders.
  2. Do all CMS-1500 submissions require a narrative or attachment? Yes, all CMS-1500 submissions (whether submitted through an XML submission partner or sent directly to the Board) require a medical narrative and/or attachment. Guidance on Medical Narrative and Attachment Requirements
    When the CMS-1500 initiative is implemented, XML submission partners will be instructed to reject CMS-1500 submissions that are not accompanied by the required medical narrative and/or attachment.
  3. Does the CMS-1500 data need to be in the same format for submission to the payer as it is to the Board? No, the Board has specific technical requirements for the electronic transfer of the CMS-1500. The payer's requirements for electronic transfer may be different. Payer requirements should be confirmed with them.
  4. Is the C-4.3 being replaced with the CMS-1500? No, it is anticipated that the C-4.3 will NOT be replaced by the required submission of the CMS-1500 form.
  5. Will a paper CMS-1500 be accepted by the Board? The Board will accept the paper form until the Chair mandates the XML submission of the CMS-1500. While the XML submission may be mandated by the Chair, if a provider certifies that he or she is unable to submit electronically, there will be a way to continue to submit using paper.
  6. Will all payers accept paper CMS-1500s in 2019 and beyond? All payers will be required to accept paper CMS-1500s until it becomes mandatory to submit the CMS-1500 via XML.
  7. Where are the descriptions of the fields for the CMS-1500 located? The CMS-1500 Field Matrix (Excel) details the box-by-box descriptions
  8. Are there any anticipated changes for facilities that bill on the UB04? There are no anticipated changes at this time for facilities that bill using the UB-04.
  9. Will all payers still accept paper C-4, C-4.2 forms in 2019? All payers will be required to accept the paper C-4, C-4.2 forms until it becomes mandatory to submit the CMS-1500 via XML.
  10. Will EOBs still come on paper in 2019? EOBs will not have a requirement by the Board until Phase 2 is implemented, at which time, payers will be required to submit EOBs electronically to their XML submission partners (clearinghouses) upon adjudication of the associated electronic CMS-1500.
  11. Will the Board accept faxed C4s during 2019? The Board will accept faxed C-4s until it becomes mandatory to submit the CMS-1500 via XML.
  12. Will the Board accept faxed CMS-1500s in 2019 and beyond? The Board will not accept faxed copies of the CMS-1500 once it becomes mandatory to submit the CMS-1500 via XML.
  13. What address and fax should be used to send a CMS-1500 and narrative? Currently bills can be submitted to the Board by fax to (877) 533-0337 or by mail (NYS Workers' Compensation Board, Central Mailing Address, PO Box 5205, Binghamton, NY 13902-5205). Providers will be required to submit the CMS-1500 via XML on or about January 1, 2020.
  14. Will there be a list of payer FEINs on the Board website? There will not be a list of FEINs on the Board's website.
  15. If there is no payer or the payer is undetermined, how will we submit only to the Board? The provider's office should obtain the employer's name and address from the injured worker. If they are unaware of the correct entity who they work for, they should contact their human resource office or supervisor. As you may know, in New York State, employers are required to post the C-105 (Notice of Compliance – Workers' Compensation Law) in a conspicuous place in the workplace identifying the employer's workers' compensation insurance carrier name, address, phone number and policy number.
  16. If EOBs will be coming electronically, how will payments be made? Will checks be sent with no EOB or will a copy of an EOB be sent with payments? The Board is not mandating a change to the payers' payment method.
  17. Who pays the XML submission partner for their services? The party utilizing the XML submission partner services would pay them based on the agreement they have with each other.
  18. If form C-8.1 part B is going to be eliminated, will C-8.1 part A be a viable form for Part A filing? It is anticipated that the C-8.1A will remain in effect. More information on the EOB and C-8.1A/HP-1 process will be available at a future date.
  19. Will the changes of each phase take effect based on the bill's date of service or the date which the bill is submitted? The changes will be effective for any bill submitted on or after the effective dates.
  20. Will the required timeframes for submitting the medical reports change as a result of this initiative? The timeframes for submitting medical reports to the Board and the payer (set forth in NYCRR 325-1.3) are not changing as a result of this initiative. The following timeframes are still required:
    • Initial CMS-1500 (formerly the C-4, OT/PT-4 or the PS-4): within 48 hours of first treatment;
    • Subsequent CMS-1500 (formerly the C-4.2, OT/PT-4 or the PS-4): 15 days after first treatment, and thereafter for continuing treatment: after each follow-up visit scheduled when medically necessary but not more than 90 days apart.
  21. When electronic submission of the EOB is implemented in Phase 2, how will the denial codes replace the objection currently on the C-8.1B and C-8.4? The Board plans to map the current objection codes to the Claims Adjustment Reason Codes (CARC) used for the X12 835 standard.
  22. Are Phases 1 and 2 of the CMS-1500 initiative voluntary? Yes, Phase 1 is voluntary. It is currently anticipated that Phase 2 will also be voluntary. The Board can not mandate that providers or insurers participate in the initiative without a regulation change. It is anticipated that the mandatory electronic transmission will be implemented in Phase 3.
  23. Will there be a regulation change when the electronic submission of the CMS-1500 becomes mandatory? Yes, there will be a change in regulation prior to the mandatory electronic submission of the CMS-1500. Stakeholders will be provided an opportunity to comment on proposed regulations. The Board anticipates there will be a 60-day comment period associated with this regulation change.

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  1. Do I need to complete a new XML Submission Agreement to submit the CMS-1500 electronically even though I already completed one to submit the EC-4NARR? No, all providers who have already completed an XML Submission Agreement to submit XML data to the Board do not need to complete a new agreement to begin submitting the CMS-1500 electronically.
  2. I'm a provider who would like to start submitting CMS-1500 forms and required medical narrative and/or attachments. Do I need to register with the Workers' Compensation Board first? All health care providers who submit CMS-1500 forms using an XML submission partner must complete the registration for XML forms submission on the Board's website before the Board will accept their electronic submission of CMS-1500 documents through the XML forms submission process. You may use any Board approved XML submission partners who have been approved to submit CMS-1500 bills and required medical narrative and/or attachments.
  3. The clearinghouse that I use is not registered as a Workers' Compensation Board XML Submission Partner. How can I submit the CMS-1500 using the XML submission process? Clearinghouses are encouraged to become XML submission partners. Clearinghouses interested in becoming an XML Submission Partner will need to register first with the Board. All submission partners must test the CMS-1500 XML submission and be approved prior to implementation. However, if your clearinghouse does not wish to become a submission partner directly, they may work with one of the approved XML submission partners.
  4. Will pharmacies and durable medical equipment (DME) providers be required to submit the CMS-1500? Pharmacies and DME providers may continue, but will not be required, to submit the CMS-1500 under this initiative.
  5. Where can I obtain insurer information for billing purposes? Providers may obtain insurer information from the claimant or by using the Employer Coverage Search tool on the Board's website.
  6. Will there be any CMS-1500 requirements for chiropractors? There are no CMS-1500 requirements specifically for chiropractors. However, chiropractors should utilize the initial and subsequent narrative report requirements as shown on the Requirements page.
  7. What if we do not have the ability to send a CMS-1500 electronically? The Board will establish a hardship exception process for providers who are unable to meet the mandatory electronic reporting requirements. The actual process to do so will be posted to the website in the future.
  8. Will all providers be required to have a National Provider Identifier (NPI) number to submit the CMS-1500 electronically? Yes, all providers will be required to have an NPI number.
  9. Why have I received a letter from the Board requesting my National Provider Identifier? The National Provider Identifier (NPI) will be used by the Board to validate electronic submission of the CMS-1500 bill.
  10. How do I provide my National Provider Identifier (NPI) to the Board? If you received a letter and you ARE a Board authorized provider and haven't registered, please refer to Registration for Health Care Providers and Independent Medical Examiners. If you are NOT a Board authorized provider, send your name, license number and National Provider Identifier (NPI) to the Board's Customer Support Unit by mail to NYS Workers' Compensation Board, Customer Support Unit, 328 State Street, Schenectady, NY 12305 or email to
  11. How do I obtain a National Provider Identifier (NPI)? You can apply for an NPI through NPPES NPI Registry.
  12. What if I do not know my National Provider Identifier (NPI)? Your NPI can be can be found by searching the NPPES NPI Registry
  13. How do I become a Board Authorized Provider? Instruction for how to Apply to Become an Authorized Provider
  14. How do I know if I have previously signed up to submit medical bills electronically? Soon, the Board will post a listing of all providers who have previously signed up for XML forms submission.
  15. How do I know which clearinghouses are planning to become a CMS-1500 XML Submission Partners? The Board has published a listing of clearinghouses who are interested, testing or approved to become an XML Submission Partner for the CMS-1500.

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XML Submission Partners

  1. I'm a medical billing clearinghouse and would like to register with the Worker's Compensation Board to become an XML submission partner. Who do I contact to register? Clearinghouses interested in becoming an XML Submission Partner will need to complete an online registration with the Board.
  2. Our organization is a current Workers' Compensation Board XML Submission Partner approved to submit the EC-4NARR. Will we need to execute a new agreement to submit the CMS-1500 in XML format? Yes, a new agreement will need to be executed.
  3. Will there be a testing phase prior to implementing the submission of CMS-1500 in XML format? Yes, you will be required to complete a testing phase to verify that you can submit a valid CMS-1500 to the Board.
  4. Is there an XML schema available? A draft CMS-1500 XML schema is available on XML Form Submission Schemas, Documentation and Samples page of the Board's website.
  5. Will the 837P or 837I format with attachment be accepted in place of the XML format? The 837P or 837I will NOT be accepted in place of the XML format.
  6. Where can I find the specifications for attaching provider narrative items (initial and follow-up reports) in XML electronic submission? There will not be a schema created to collect medical narratives/attachments. The attachments need to be a TIF or text file modeled after the narrative attachment requirements found on the requirements page. Sample submissions can be found on the XML Form Submission Schemas, Documentation and Samples.
  7. Besides the XML rendering for the CMS-1500, what must be contained in the XML file transmitted to the Workers' Compensation Board? Each CMS-1500 submitted via XML must include a TIFF-formatted medical narrative and a TIFF-formatted image of the completed CMS-1500.
  8. Do all clearinghouses need to become XML submission partners? No, only those clearinghouses that are sending XML files to the Workers' Compensation Board need to become XML submission partners.
  9. What will be included in the test plan? There will be two components to the test plan: 1) Preliminary; and 2) Parallel. Preliminary testing is required to allow the XML partner to demonstrate to the Board that they can construct a submission that is properly formatted. It is not necessary to use production data for preliminary testing. Parallel testing will occur after successful preliminary testing. This is to ensure that data received electronically from the medical provider is properly mapped to the submitted XML file and CMS-1500 image, and that the same information (mapped fields) submitted by the provider on the current production form is contained in the parallel test submission. Before the parallel test phase begins, the submitter needs to identify medical providers and payers to participate in the testing phase with them. Additional details of the test plan is available in the CMS-1500 Onboarding Instructions adobe pdf.
  10. Where do the XML submission partners obtain the WCB authorization number and rating code? The Board will post a file on its website of WCB authorization numbers and rating codes. This file will be available before the start of testing.
  11. How will I know the payer acknowledgment date if the CMS-1500 has not been sent electronically to the payer? The payer acknowledgment date will not be required for paper submissions.
  12. What is the timing of submission of the CMS-1500 to the WCB? The CMS-1500 forms and medical narrative reports should be submitted to the Board immediately upon acknowledgment by the payer and no later than seven business days after receipt from the treating provider.
  13. If any non-required field is unknown to the XML submission partner, e.g. claimant's social security number, how should this be transmitted to the Board? Are there default values that should be used in these cases such as "Unknown" or "999999999"? If the XML submission partner does not have the data for a non-required field, the field should be left blank.

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  1. What information will a payer be required to submit to the XML submission partner upon receipt of a CMS-1500 bill? The payer must submit the following information to the XML submission partner:
    • Insurer Acknowledgment Date [YYYY-MM-DD]
    • Insurer W Number
    • WCB Case Number (if assembled)
  2. If a payer has no claim on record for a specific injury date, is it required to accept a CMS-1500 from an XML submission partner? Yes, a payer may not reject a CMS-1500 from the XML submission partner if a claim (FROI) has not yet been received.
  3. Will all payers be required to accept the CMS-1500s electronically? All payers will be required to accept the CMS-1500 electronically when it becomes mandatory in Phase 3. Web submission via the Board's website will not be available.
  4. Will the payer be required to issue C-8.1 for any bill missing a narrative or will the EOB stating the omission be sufficient? The electronic submission of the EOB will not begin until a later phase of this initiative. This process is still under development, however the Board plans to use EOB denial codes to replace those objection reasons currently on the C-8.1B and C-8.4. Please continue to monitor the Board's website for updates on this information.
  5. How will payers know what XML submission partner the provider is using? Payers will be responsible for returning an acknowledgement of receipt back to the clearinghouse from which they received the CMS-1500 billing data/medical narrative attachments.
  6. At what point does the 45-day rule start for payment? The payer must remit payment within 45 days from when the bill is received by the payer's clearinghouse or the payer themselves (whichever is earlier).
  7. We are a third-party administrator who handles claims for self-insured employers and insurance carriers, will our information be captured anywhere on the CMS-1500? Yes, third-party administrator information will be captured in CMS item 0 (payer name, address, city state and zip). If known, the carrier W number should be entered in item 0 (carrier W#).
  8. How do I know which clearinghouses are planning to become a CMS-1500 XML submission partners? The Board has published a listing of clearinghouses who are interested, testing or approved to become an XML Submission Partner for the CMS-1500.

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