DWC is proposing additional amendments to the draft regulations implementing the new California Workers' Compensation Information System (WCIS) in response to comments received on the draft recently circulated for public review.
The proposed changes will move the mandatory date for claims administrators to submit electronic reports into the system to March 1, 2000 from Sept. 1, 1999. The revisions will also temporarily remove certain data elements related to reporting of medical services, specifically the doctor's initial diagnosis for all claims and comprehensive medical data for a subsample of claims.
In addition, variance application procedures have been clarified and simplified, and other data requirements have been clarified, particularly to indicate those circumstances in which particular data elements need not be provided. Some data elements have been eliminated permanently.
The new amendments are considered "substantive" and therefore require a new 15-day public comment period, which ends July 14, 1999. This will complete a 10-month process of gathering and responding to public input in order to balance the WCIS mandate against the interests of the regulated community. The final step will be to forward adopted regulations to the state Office of Administrative Law for review and approval.
DWC temporarily removed the medical data reporting requirements in response to public concerns that the statutorily mandated model, EDI standards adopted by the International Association of Industrial Accident Boards and Commissions, were not yet finished. DWC is resolved to restore this section as soon as feasible. However, this means that claims administrators must continue to file doctor's first reports in a paper format until these rules can be finalized.
In addition, many carriers have indicated that resolving Y2K issues will prevent them from implementing any new computer systems over the balance of this year. Those who will not be ready on time may request a variance to delay reporting, but it appears that this is a significant issue with enough participants to warrant changing the mandatory start date.
DWC will still be prepared to begin accepting electronic first reports on Sept. 1, so claims administrators who are ready and wish to begin benefiting from paperless reporting will be able to do so on a voluntary basis on that date. Many multi-state organizations already experienced in electronic reporting in other states have indicated that they are looking forward to participating in the California system as rapidly as possible.
Carriers must still begin submitting subsequent reports by July 1, 2000, as currently proposed, and annual summaries must be reported into the system beginning Jan. 1, 2001, another date which is unchanged. Those who will still not be prepared to begin submitting first reports on March 1, 2000 and who have requested and received a variance to delay reporting must begin by Jan. 1, 2001 under the new proposals.
Electronic reporting (EDI) technology is well established and currently in use for workers' compensation filings in about twenty states. Although implementing EDI necessitates some up-front investment for participants, it will ultimately reduce costs by eliminating needless paper handling.
The WCIS was mandated as part of the 1993 reforms of the California workers' compensation system. It will help policymakers by providing, for the first time, comprehensive data and an overview on how well the state's workers' compensation system is performing.