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Subject Number 046-1362R2 Important Updates Regarding Forms C-8.1 and C-8.4, Including Implementation Dates Related to the CMS-1500 Initiative

Board Bulletins and Subject Numbers

Revision to Subject Number 046-1362R, released on June 16, 2021

February 23, 2022

The Board has made a number of important updates regarding the Notice of Treatment Issue/Disputed Bill (Form C-8.1) and Notice to Health Care Provider and Injured Worker of a Carrier's Refusal to Pay All (or a Portion of) a Medical Bill Due to Valuation Objection(s) (Form C-8.4). These updates, detailed below, include an immediate change to the reporting of Social Security numbers, as well as revisions to Forms C-8.1 and C-8.4 as part of the Board's transition to the universal billing form, the CMS-1500. The Board will be issuing new versions of Forms C-8.1 and C-8.4 this spring and is restating the payer implementation schedule related to the CMS-1500 initiative.

Social Security Numbers

After a review of the C-8.1 and C-8.4 forms, the Board determined it would no longer require inclusion of an injured worker's full nine-digit Social Security number, as of June 16, 2021. Instead, only the last four digits of the Social Security number should be included on the current paper forms. Payers completing the paper version of these forms should provide the last four digits of the injured worker's Social Security number in the following format: XXX-XX-1234.

CMS-1500 Initiative

The C-8.1 and C-8.4 forms have been updated and will be published in May 2022 to clarify potential objections and to eliminate certain obsolete sections currently found on the left side of Form C-8.1, entitled: Part A Notice of Objection Regarding Further or Future Treatment. The objection reason currently listed under Part A of Form C-8.1, "Requested treatment is not for an established site or condition," will be moved to the Request for Further Action by Carrier/Employer (Form RFA-2); a new version of Form RFA-2 will be published in May 2022. Form C-8.1 will be renamed Form C-8.1B.

The new C-8.1B and C-8.4 forms will become effective July 1, 2022, and will become mandatory 45 days after the effective date of August 15, 2022. At that point, the current versions of the forms will not be accepted, and no action will be taken by the Board should a payer continue to use them.

Effective October 1, 2021, payers were required to:

Effective November 1, 2021, payers were required to:

Effective July 1, 2022, payers must:

Payer Objection Period: As a reminder, payers must remit payment or object to payment of a medical bill within 45 calendar days from when the bill is received. The acknowledgement date transmitted by the payer to the XML submission partner and also displayed on the CMS-1500 form (field 19) is the start date for the 45-day period. If the bill is not submitted electronically, the 45-day period will start on the date the bill was received by the Board.

Payer Notice to Providers: Payers have the option of sharing Forms C-8.1B and C-8.4 with providers by offering secure online access to their systems. However, if they choose to do so, they must notify providers via email each time documents are available to be downloaded or viewed. Such emailed notification must include:

Questions regarding use of the new forms or any of the CMS-1500 requirements, as well as requests for a copy of the C-8.1B and C-8.4 forms prior to the May 2022 publication date, should be sent to

Clarissa M. Rodriguez