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April 23, 2026

Recently, the Department of Labor and Industry (DLI) has noticed an increase in the number of questions about payment or denial of medical bills. Payer and health care provider payment and billing responsibilities are outlined in Minn. Stat. § 176.135, subds. 6 and 7, and Minn. R. part 5221.0600. Excessive charges are covered under Minn. R. part 5221.0500. 

What are a health care provider’s responsibilities related to billing? 

  • A health care provider must electronically submit an itemized statement of charges on the prescribed billing form to the payer within 60 days of the service and submit copies of medical records or reports that substantiate the nature of the charges and their relationship to the work injury. A health care provider cannot attempt to collect or initiate any action for collection of the charge until the further information required has been furnished. 

    • Under Minn. Stat. § 176.136, subd. 2a, the commissioner may assess penalties, costs and expenses against a health care provider that collects or attempts to collect payment from an employee in violation of the workers’ compensation law. 

  • If the insurer has denied primary liability, the health care provider can bill the employee. 

  • If the employee’s health insurance pays the medical expenses on a denied claim, the insurance company has a right to reimbursement if it is later determined the charges are due to a compensable injury. 

What are the payer’s responsibilities related to payment or denial of medical bills? 

As soon as reasonably possible, but no later than 30 calendar days after receiving the charge for service and the supporting medical records, the insurer must: 

  • pay the charge or any portion of the charge that is not denied; 

  • if more information is needed, make a request for specific additional information to substantiate the nature of the charge and its relationship to the work injury (when the requested information is received, the insurer has 30 days to either pay or deny the charge in question); 

  • deny all or part of the charge if it is not compensable; or 

  • deny all or part of the charge if the charge is excessive. 

    • If the charge is denied, the insurer must send the provider a written notification outlining the basis of the denial by the 30-day deadline. A copy of the notification must be sent to the employee. 

What about excessive charges? 

  • Denying all or a portion of a medical bill on the basis the charge or charges are excessive may only be done in certain circumstances, as detailed under Minn. Stat. 176.136, subd. 2, and Minn. R. part 5221.0500, subpart 1. 

  • Bills may not be denied on the basis that the charge is excessive solely because there are cheaper alternatives for the same service, article or supply available from other places, such as an online retailer. 

Failure to comply with these requirements may subject the payer to penalties. 

Where to get more information? 

For answers to questions about medical records, email DLI’s medical policy staff at medical.policy.dli@state.mn.us