Major Updates to Form C-8.1B

by Rosalind Asch-Hobeck

Major Updates to Form C-8.1B: Greater Transparency and Accountability in Objections to Medical Bills

The New York State Workers’ Compensation Board has announced important revisions to Form C-8.1B — Notice of Objection to a Payment of a Bill for Treatment Provided. This form is used by carriers, self-insured employers, and third-party administrators to officially notify the Board, claimants, attorneys, and medical providers when payment for a medical bill is being disputed.

These changes are part of the Board’s broader effort to improve communication, increase transparency, and ensure timely resolution of billing disputes in the workers’ compensation system. The revisions affect both the paper and online versions of the form and will become mandatory on January 5, 2026.

Expanded Narrative Requirements: Detailed Explanations Now Required

Historically, many objections submitted with the C-8.1B form contained only brief or generic statements. This sometimes led to confusion, delayed adjudication, and unnecessary hearings, as parties were left guessing about the exact basis for the payer’s objection. To address this problem, the Board has strengthened the form’s requirements regarding narrative detail.

Under the updated structure, payers must now provide clear, specific, and factual explanations when objecting to payment of a bill:

• If the objection is based on any of the reasons listed in Boxes 1–11, the payer must use Box 12 to enter a detailed explanation of the basis for the objection.

• If the objection falls under Boxes 13–19, the payer must use Box 20 to provide both the explanation and the relevant Medical Treatment Guidelines (MTG)Reference Code.

The Board expects these explanations to include meaningful narrative details, not boilerplate language. This may involve references to treatment dates, injury sites, applicable sections of the Medical Treatment Guidelines, and other relevant facts that clarify the rationale for the objection.

Failure to provide a sufficiently detailed explanation in Box 12 or Box 20 may result in the C-8.1B being deemed incomplete, and the payer’s objection may be denied on procedural grounds. This is a significant change that places a higher burden of clarity and documentation on carriers and administrators when disputing medical treatment bills.

Revised Certification Section: Broader Notification Obligations

Another important update involves the certification statement at the bottom of Form C-8.1B. Under 12 NYCRR 325-1.25(c)(1), the payer is required to notify multiple parties whenever a medical bill is not being paid.

The previous version of the form required certification that a copy had been sent only to the health care provider. The revised form now requires certification that copies were sent to:

• The medical provider,
• The claimant,
• The claimant’s attorney, if one is on file, and
• The Workers’ Compensation Board.

This expanded certification reflects the Board’s expectation that all affected parties be promptly informed of the reasons for a non-payment. In practical terms, this should lead to fewer delays, better communication among parties, and a clearer understanding of the issues in dispute from the outset.

Why These Changes Matter

The C-8.1B form plays a critical role in the New York workers’ compensation system. It is the primary mechanism through which carriers and employers document their objections to medical bills. A properly completed form provides not only notice of the objection but also the legal and medical basis for it, ensuring that providers, claimants, and the Board can respond appropriately.

By requiring greater specificity and broader notification, the Board aims to streamline dispute resolution, reduce unnecessary litigation, and improve overall case efficiency. Carriers and third-party administrators should review their internal workflows to make sure staff responsible for handling medical billing objections are fully trained on these new requirements.

If a C-8.1B form is not completed in full in accordance with the new requirements, the Board is likely to deny the objection outright and may also impose penalties. In the past, carriers and administrators often attached Explanations of Benefits (EOBs) to support their objections, but this practice will no longer be sufficient. The Board now requires that all relevant information and the detailed basis for the objection be clearly set forth on the form itself with enough specificity to meet the regulatory standard.

Effective Date and Compliance Considerations

The updated paper version of Form C-8.1B is now available on the Board’s website. Beginning January 5, 2026, all payers must use the new form. After that date, older versions will not be accepted.

The Board also intends to update the online version of the form in its electronic filing system to align with these new requirements. Employers, insurers, and TPAs should update their internal templates, train staff, and test their systems well in advance to ensure a smooth transition.

Failure to comply with the revised requirements could result in delayed processing, denial of objections, or potential exposure to payment obligations that could have been avoided had proper documentation been provided.

Questions and Additional Resources

For more information or to obtain the updated form, visit the Forms page on the New York Workers’ Compensation Board website at www.wcb.ny.gov.

Key Takeaway: Starting January 5, 2026, payers must provide detailed narrative explanations when objecting to medical bills, and they must notify all relevant parties — not just the provider. Carriers, TPAs, and employers should act now to align their internal procedures with the Board’s new requirements to avoid processing delays or adverse findings.