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California workers' comp

How to read a California workers' comp explanation of review (EOR)

Every reduction on a workers' comp bill arrives on an explanation of review. The EOR is where you find out what the carrier paid, why, and how long you have to object. Most practices post the payment and move on. Reading it line by line is how you find the money.

What it is
The document a claims administrator must send "upon payment, adjustment, or denial" of a bill (Labor Code 4603.3; 8 CCR 9792.5.4(f))
When it arrives
Paper bills: an objection within 30 days and payment within 45 days of receipt, or 60 for a governmental employer (LC 4603.2(b)). E-bills: within 15 working days (LC 4603.4)
Codes it uses
Paper: DWC Bill Adjustment Reason Codes. Electronic: CARC and RARC codes on the 835 (DWC Medical Billing and Payment Guide, Appendix B)
Your clock
90 days from service of the EOR to request second bill review (8 CCR 9792.5.5)
If it's late
Uncontested amounts not paid on time are owed at the fee schedule plus 15%, with interest (LC 4603.2(b)(2))

What every EOR must tell you

Labor Code 4603.3(a) sets the minimum. For every bill, the EOR must include:

  1. The items or procedures billed and the amount you asked for.
  2. The amount paid.
  3. The basis for any adjustment, change or denial of each item.
  4. For an incomplete bill, the additional information needed to decide it.
  5. For a denial that isn't a fee dispute, the reason for the denial.
  6. Whom to contact if a dispute arises over the payment.

It must also tell you the time limit to object and how to get Independent Bill Review. The DWC guide prescribes the wording: a section headed "TIME LIMITS TO DISPUTE PAYMENT AMOUNT" (Appendix B, Table 3.0). An EOR missing any of these is defective, and that's worth noting in your second review.

The reason codes that matter most

Paper EORs carry DWC Bill Adjustment Reason Codes. Electronic 835s carry the Claim Adjustment Reason Code (CARC) the DWC maps each one to. Four account for many of the reductions worth a second look:

G1 / CARC W1
Fee schedule
"The charge exceeds the Official Medical Fee Schedule allowance. The charge has been adjusted to the scheduled allowance." Check: is the paid amount actually the OMFS amount for that code, date of service and locality?
G4 / CARC 45
Contract or PPO
"This charge was adjusted to comply with the rate and rules of the contract indicated." The payer must name the contract. Check: did your practice sign that network?
G8 / CARC 97
Bundled
"A charge was made for a 'separate procedure' that does not meet the criteria for separate payment." On 835s, CARC 97 is also used for other bundling. Check: the modifiers. An E/M with modifier 25, documented as significant and separately identifiable, is payable under the NCCI rules California adopts (8 CCR 9789.12.13).
G57 / CARC 197
No authorization
"This service requires prior authorization and none was identified." Check: was an authorization number on the bill, or in the file?

Code text quoted from the DWC Medical Billing and Payment Guide, version 1.2.2, Appendix B, Table 1.0.

A worked example

An orthopedic office in Sacramento bills a knee injury: an established-patient visit, an injection and an X-ray on April 14, 2026, and an MRI on April 21. The EOR comes back like this:

LineBilledOMFS maximumPaidReason givenVerdict
99214-25 office visit$260.00$226.57$0.00CARC 97: included in another serviceChallenge. Modifier 25 and a separate note support separate payment.
20610 knee injection$450.00$114.39$114.39CARC W1: fee scheduleCorrect. Paid the schedule amount.
73562 knee X-ray$160.00$74.40$63.24CARC 45: 15% network discountCheck the contract. If the practice never signed that network, it's improper.
73721 MRI (4/21)$2,100.00$355.77$0.00CARC 197: no authorizationChallenge. The authorization number was on the bill.
Total$2,970.00$771.13$177.63$593.50 still recoverable, inside 90 days

The billed charge doesn't matter much. What matters is the gap between the OMFS maximum and what was paid, and whether the stated reason is true. Here the carrier was right about one line out of four. See how this bill gets appealed, step by step.

OMFS maximums are base maximum fees under 8 CCR 9789.12.2 for an office (place of service 11) in the Sacramento locality, from the CMS RVU26B file and the $51.6091 conversion factor adopted in 8 CCR 9789.19(m) (DWC OMFS), computed by Redress's fee schedule engine. The visit, bill and carrier responses are illustrative.

Check every line in five steps

  1. Match lines. Line up each billed code and modifier with the EOR. A line missing from the EOR is an unanswered bill, not a denial.
  2. Price the line. Look up the OMFS maximum for the code, modifiers, date of service, place of service and locality. That number, not your charge, is what the carrier owes for a correctly billed, payable service.
  3. Read the reason. Translate the code (above) and note any remark codes.
  4. Test the reason. Is the contract real? Was there an authorization? Do the modifiers and notes support separate payment? Was the paid amount actually the schedule amount?
  5. Calendar the deadline. 90 days from service of the EOR. If it came by mail without proof of service, service is deemed five calendar days after the postmark (8 CCR 9792.5.5(b)).

PPO discounts: make them prove it

Network discounts are where many reductions hide, and California gives providers unusually strong tools. Labor Code 4609 requires the EOR to identify "the name of the network with which the payor has an agreement that entitles them to pay a preferred rate." If you ask in writing, the payor must "demonstrate that it is entitled to pay a contracted rate within 30 business days." If it can't, it owes the lesser of your fee or the fee schedule within 10 days of your written notice, and it can't take further discounts from you without your express written consent (LC 4609(c)).

When the EOR is late, or never comes

For a complete, properly documented bill, the carrier must pay at the fee schedule and explain any contested items within the deadlines above. If it doesn't, the uncontested amount is owed at the schedule "increased by 15 percent, together with interest at the same rate as judgments in civil actions" from the date the bill was received (LC 4603.2(b)(2)). The DWC guide calls the increase and interest "self-executing" (ยง6.4(b)): you bill for them and they're owed without a hearing.

What to do with a reduction that's wrong

Request a second bill review within 90 days of service of the EOR. If the only dispute is the amount and you miss that window, the bill "shall be deemed satisfied" (LC 4603.2(e)). If the second review doesn't fix it, you have 30 days to request Independent Bill Review, where providers win roughly nine times in ten. The appeal guide walks through both steps.

Find out what is still inside the window.

Send us twelve months of explanations of review. We price every line to the fee schedule and send back a one-page report: what was improperly reduced, and how much you can still challenge. Free, with a BAA first.

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Sources
  1. Labor Code 4603.3, explanation of review
  2. Labor Code 4603.2, payment deadlines, penalty and second review
  3. Labor Code 4603.4, electronic billing and payment
  4. Labor Code 4609, network (PPO) discounts
  5. 8 CCR 9792.5.4, definitions including explanation of review
  6. 8 CCR 9792.5.3, billing guide is binding on claims administrators
  7. 8 CCR 9792.5.5, second review
  8. 8 CCR 9789.12.13, Correct Coding Initiative
  9. DWC Medical Billing and Payment Guide v1.2.2 (Appendix B reason codes)
  10. DWC Official Medical Fee Schedule

Last reviewed October 14, 2026. This guide is general information about California workers' compensation billing rules, not legal advice. Check the current statute and regulation before filing.