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FAQs -- Rehabilitation providers

This information is intended to answer common questions about rehabilitation services provided during a workers' compensation case including frequently asked questions the Department of Labor and Industry (DLI) receives from qualified rehabilitation consultants (QRCs), insurers and injured workers. It is for educational purposes only, is not a complete description of workers' compensation law or of the topics discussed, and should not be construed as offering or providing legal advice.

New FAQs as of July 2025

1. How can rehabilitation services help with a workers' compensation claim?

Rehabilitation is intended to assist an injured employee so the employee may return to a job related to the employee's former employment or to a job in another work area that produces an economic status as close as possible to that the employee would have enjoyed without disability.

2. When is a rehabilitation referral required and what is the timeframe to make a referral?

If an injured worker meets certain criteria regarding return-to-work status, a rehabilitation consultation is required. See Minnesota Rules 5220.0110, subpart 7. A referral is required:

  • within 14 calendar days after it becomes known the temporary total disability will likely exceed 13 cumulative weeks; 

  • within 90 calendar days of the date of injury when the employee has not returned to work following a work injury; or 

  • within 14 calendar days after receiving a request for rehabilitation consultation, whichever is earlier. 

A rehabilitation consultation can also be requested by the employee or can be provided on agreement of the parties at any time during the claim process.

The referral must be reported to DLI through the Disability Status Report (DSR) within the appropriate timeframe above.

3. What if an injured workers has plans to return to work with their date-of-injury employer in the future?

If rehabilitation services are not needed because there is a scheduled return to work with their date-of-injury employer, a request for waiver of rehabilitation services can be submitted to the DLI. The waiver must be requested within the timelines specified above.

A request for a waiver of rehabilitation services is reviewed by the DLI Compliance, Records and Training unit. The request is complete when the DSR is submitted and contains the following information, required under Minn. R. 5220.0110, subp. 7:

  • identifying information about the employee, employer and insurer;

  • information about the duration of disability and the likelihood the disability will extend beyond 13 weeks;

  • the current work status of the employee;

  • an indication of whether the employer will return the employee to work;

  • information about accommodations or services being provided to the employee to assist in the return to the date-of-injury employer;

  • an indication of whether a rehabilitation consultation is occurring or a request for a waiver of consultation is being made under Minn. R. 5220.0120;

  • if rehabilitation consultation is indicated, the name of the qualified rehabilitation consultant who will conduct the rehabilitation consultation; and

  • a current treating physician's work ability report must be attached to the form.

A DSR request missing any of the listed information will be rejected and referral for rehabilitation services will be required at that time.

If rehabilitation services are not offered or other appropriate filings are not completed within the required timelines, this could lead to a commissioner-ordered consultation by DLI. These efforts help to ensure injured workers in Minnesota are offered the appropriate services to help them return to work and to pre-injury levels of functioning as quickly as possible. This benefits not only the employee, but also the employer, the employee's coworkers and the employment system in Minnesota.

4. Where do I file a motion to intervene?

The Notice of Right to Intervene is meant to inform parties if the dispute is at the Court of Administrative Hearings (CAH) or DLI.

  • Remember, CAH and DLI are completely separate entities and do not have the same electronic filing system.

If the dispute is at DLI, the motion to intervene must be filed in Work Comp Campus.

If the dispute is at CAH, the motion to intervene must be filed in C-Track.

5. If one QRC firm is providing vocational rehabilitation services, can another QRC firm provide job placement or job development services?

No, job placement and job development services can only be provided by a rehabilitation vendor or the QRC firm that employs the assigned QRC or QRC intern. See Minn. R. 5220.1250. 

6. What regulations does DLI have around QRCs working as disability case managers (DCMs)?

DLI does not regulate DCMs. However, DLI does regulate and enforce the roles and responsibilities of QRCs. If you are a QRC acting as a DCM, you cannot also work as that employee's QRC because that contradicts professional conduct requirements. See Minn. R. 5220.1801.

7. When does a request for retraining have to be made and how long are retraining benefits available?

Retraining is limited to 156 weeks.

Temporary total disability (TTD) compensation is payable for up to 90 days after the end of a retraining plan.

  • Compensation for wage loss is not limited to the 275- or 450-week limitations outlined in Minnesota Statutes § 176.101, subdivision 1 and 2, when an injured worker is in retraining.

A request for retraining must be filed before 208 weeks of any combination of wage-loss benefits (TTD or temporary partial disability (TPD)) have been paid.

  • Retraining can be provided after 208 weeks if the request for retraining was made to the commissioner before 208 weeks.

  • Notice about this limitation must be made before 80 weeks of TTD or TPD is paid, regardless of the number of weeks since the date of injury.

    • If notice is not given within 80 weeks, the time to make a request for retraining extends to 225 weeks.

8. What are some general guidelines for billing of rehabilitation services?

A rehabilitation provider may only bill for necessary and reasonable services that are rendered according to Minnesota Statutes. 

  • Refer to Minn. R. 5220.1900 for guidelines and requirements related to rehabilitation provider billings, such as what needs to be on the invoice, what services can be billed, what activities require approval and what activities are not billable.

  • Payments for rehabilitation services should be paid as soon as reasonably possible and must be paid no later than 30 calendar days after receiving the bill. The insurer must pay the charge or any portion of the charge that is not denied, deny all or a part of the charge stating the specific service charge and the reason it is excessive or unreasonable, or specify the additional data needed, with written notification to the rehabilitation provider within that 30-day timeframe.

Note that under Minn. R. 5220.1801, subp. 9, QRCs must not engage in fraudulent billing practices.

Under Minn. R. 5220.1805, a rehabilitation provider must advise the referral source and payer of its fees and reporting procedures in advance of rendering any services and also furnish, upon request, detailed and accurate time records regarding any bills in question.

9. How do you calculate interest on an unpaid rehabilitation invoice?

While DLI does not assist with interest calculations, the information below can be used to help calculate interest due for QRC bills.

Interest does not compound. Per Minn. Stat. § 549.09, subd. 1, interest is computed on a "per annum" basis calculated by the formula outlined here and is applied in weekly increments.

Formula for calculating interest on a lump-sum payment

The interest rate is determined per Minn. Stat. § 176.221, subd. 7, "for charges overdue from Jan. 1, 2008, through the present date, interest is payable at a rate of 4%."

10. A rehabilitation-related document was filed on the wrong case or claim in Campus, what do I do?

If you have filed a document in the wrong case or see a document that was misfiled, submit a ticket to the Workers' Compensation Help Desk explaining the mistake and asking for the document to be removed. DLI will investigate and, if appropriate, remove the misfiled document. You can submit a ticket to the help desk by phone at 651-284-5005 (press 3), 800-342-5354 (press 3) or helpdesk.dli@state.mn.us.

11. There are errors in a rehabilitation-related document I submitted, what do I do?

If a rehabilitation document was submitted with incorrect or missing information, then a new document needs to be submitted in Campus.

If the document submitted was an R-form that cannot be redone in Campus, then you will need to manually upload the corrected or amended version.

Forms are available on DLI's Work comp:  Forms webpage. When complete, use the "Submit a Filing" function to submit a corrected R-form and make a note in the "Description" field to clarify this form has been amended or updated.

  1. Go to the "Rehabilitation Transaction (RT)" and select "Submit a Filing" in the upper right corner.

  2.  Select "Upload Document" under "Upload Your Filing."

  3. Complete the screen as follows (example is for an R-2 Rehabilitation Plan form, edit the "Description" as appropriate for other forms).

  4. Sign and select "Submit."

Upload document

12. I am a QRC and I am retiring. What do I need to do to notify DLI?

When a QRC is ready to retire, they should send an email message to the DLI rehabilitation registration specialist. The specialist will work with the QRC to confirm their final work day and make the Campus account inactive as of that date.

13. When a QRC changes firms, can they take their clients with them?

See the Rehabilitation Rights and Responsibilities of the Injured Worker form.

General questions and issues

1. I am working as a qualified rehabilitation consultant (QRC) intern. How should I sign my name on R-forms, reports or correspondence?

The rules require that the intern sign their name with the intern designation. "QRC intern" should be written after your name per Minnesota Rules 5220.1400, subp. 3a.

Additionally, the rehabilitation provider must indicate the number assigned by the commissioner on all reports submitted by the rehabilitation provider per Minnesota Rules 5220.1803, subp. 5. 

Example:  Valerie Bieser, QRC intern #313

2. What is the definition of a required progress report?

Minnesota Rules 5220.1802 refers to "required progress records" in some places and to "required rehabilitation reports" in other places.

A "required progress record" is a record maintained by the rehabilitation provider that documents the rehabilitation provider's services and the employee's rehabilitation progress. The record must include all case notes and written reports, whether or not they are submitted to the commissioner, and all correspondence received or prepared by the rehabilitation provider about an employee's rehabilitation. See Minn. Rules 5220.0100, subp. 30.

A "required rehabilitation report" is a rehabilitation consultation report, a plan progress report or any other report that must be submitted to the commissioner whenever a rehabilitation plan is initiated, proposed to be amended, suspended or closed, or when a change of assigned qualified rehabilitation consultant occurs. See Minn. Rules 5220.0100, subp. 31.

3. What should the qualified rehabilitation consultant (QRC) do if a party does not sign an R-2 or R-3 form?

If a party does not sign an R-2 or R-3 form, Minnesota Rules 5220.0410 and 5220.0510 specify what options are available to that person. The QRC would be encouraged to contact the party to see if there is an objection and if it can be resolved. If not, the objecting party must file a Rehabilitation Request form with DLI within 15 days of receipt of the proposed plan.

4. The insurer's independent medical examination (IME) released the employee to return to work with restrictions, but the treating doctor indicates the employee should remain off work. Can the qualified rehabilitation consultant (QRC) proceed with placement services?

Because an IME is part of claims adjustment, a QRC should not use the IME report recommendations to develop or implement the rehabilitation plan. See Minnesota Rules 5220.1801, subp. 8B.

If the insurer wants the IME report recommendations used to develop or implement the rehabilitation plan, the insurer may file a Rehabilitation Request form with the Department of Labor and Industry. If ordered by a mediator/arbitrator or compensation judge, the QRC must then follow the IME physical restrictions.

Rehabilitation consultation

1. How does an employee make a request for a rehabilitation consultation?

Employees usually call the adjuster to ask for a consultation with a qualified rehabilitation consultant (QRC); most adjusters accommodate an oral request. However, Minnesota Rules 5220.0110, subp. 6, anticipates the request will be in writing. A written request documents the date the request was made in the event of a dispute. No particular form is required.

2. Does a narrative report have to be attached to the Rehabilitation Consultation Report (RCR) form? If so, how long does the report need to be?

It is required that a narrative report be attached to the RCR form explaining why the employee has or has not been found to be a qualified employee. There is no set length. However, the qualified rehabilitation consultant (QRC) needs to explain their rationale so the parties will understand how the decision was made. See Minnesota Rules 5220.0130, subp. 3(C).

R-2 Rehabilitation Plan

1. A rehabilitation consultation was performed that determined the employee to be "qualified" to receive rehabilitation services. However, prior to the development of the R-2 Rehabilitation Plan form, the treating physician determined the employee had no further effects of the work injury and released him to return to work without any physical restrictions. What R-form should be completed?

The qualified rehabilitation consultant (QRC) should submit an amended Rehabilitation Consultation Report form, with narrative report, stating the employee is not a qualified employee, so is not eligible to receive rehabilitation services. Should any of the parties disagree with the QRC's amended assessment, they may contact the QRC to discuss their concerns and/or file a Rehabilitation Request form with the department.

2. What must be attached to the R-2 plan when it is filed?

Minnesota Rules 5220.1803, subp. 5, requires an initial evaluation narrative report about the employee that includes the following information in summary fashion:  medical status, vocational history, educational history, social history, relevant economic factors, transferable skills, employment barriers and recommendations. Narrative information on the R-2 form itself does not satisfy this requirement.

3. When must a qualified rehabilitation consultant (QRC) send the R-2 form to the Workers' Compensation Division?

The QRC must file the R-2 form with the commissioner within 45 days of the first in-person contact between the QRC and the employee or within 15 days of circulation to the parties, whichever is earlier. See Minnesota Rules 5220.0410, subp. 5.

If the QRC does not have all of the signatures at the applicable 15- or 45-day filing deadline, the QRC must file the copy with the signature(s) that have been obtained along with a letter or other evidence of the date the plan was sent to each party as required by Minnesota Rules 5220.0410, subp. 6.

4. What should I do if the insurer or employee does not sign and return the R-2 plan as required within 15 days?

Minnesota Rules 5220.0410, subp. 6, requires the R-2 form to be filed with the department with evidence (such as a copy of the letter sent to the party who didn't sign the R-form) of the date the plan was sent to each party. The plan will be deemed approved when received by the department.

R-3 Rehabilitation Plan Amendment

1. Is an R-3 form required when there is a change of qualified rehabilitation consultant (QRC) within the same rehabilitation firm?

Yes, it is required. See Minnesota Rules 5220.0710, subp. 2, and 5220.0510, subp. 3a.

2. When an R-3 Rehabilitation Plan Amendment form is filed for the purpose of extending the existing plan, but there is no change in services, must the services be listed on the form?

Yes, the services must be listed.

3. When filing an R-3 form, under item 16 (plan costs to date), does this include vendor-placement costs and projections of costs to complete the plan?

Yes, those items are included. See Minnesota Rules 5220.1802, subp. 4.

4. When may an R-3 Rehabilitation Plan Amendment form be used to fulfill the requirement for filing a Plan Progress Report form?

The Plan Progress Report form is not required to be completed if the R-3 Rehabilitation Plan Amendment form contains the information in subpart 2, items A through E, and is filed within 15 days before or 15 days after six months have passed from the date the rehabilitation plan was filed. On the R-3 form, questions 20 through 23 need to be answered. See Minnesota Rules 5220.0450, subp. 3.

R-8 Notice of Rehabilitation Plan Closure

1. If an employee no longer wishes to have rehabilitation assistance, can the file be closed? What closure category should be used on the R-8?

A qualified rehabilitation consultant may only close the case if the employee, employee's attorney and the insurer agree, using the category of agreement of the parties. See Minnesota Rules 5220.0510, subp. 7 C.

2. If an award on stipulation for settlement has been issued, can an R-8 form to close the rehabilitation file be submitted to the department even if the QRC has not received a copy of the stipulation?

If the employee/employee’s attorney and the insurer tell you an award on stipulation or a mediation award has been issued that closes out entitlement to future rehabilitation benefits, you may close a rehabilitation case and check box B (Award on stipulation/mediation) in item 21 on the R-8 form. You do not have to have a copy of the stipulation in your possession.

Note:  Document the source, who reported the award, and the reason for closure of the rehabilitation plan in the R-8 summary of rehabilitation services report (Minnesota Rules 5220.0510, subp. 7F(4)).

3. Should the R-8 narrative report discuss all the services provided during the rehabilitation plan from start to finish?

Yes, Minnesota Rules 5220.0510, subp. 7F(4), requires the qualified rehabilitation consultant to provide a summary of the rehabilitation services provided and rehabilitation costs by all rehabilitation providers.

Job placement

1. May an employee decline job-placement services?

Yes, an employee may decline the services. If the employee is represented by an attorney, the employee certainly should discuss the situation with the attorney before making the final decision about declining available services. Employees not represented should be encouraged to call the Department of Labor and Industry's (DLI's) Alternative Dispute Resolution unit at 651-284-5032 or 800-342-5354.

If the employee (or the insurer) disagrees with any major part of the rehabilitation plan, any party or the qualified rehabilitation consultant may file a Rehabilitation Request form and, if necessary, DLI or the Court of Administrative Hearings will then decide the issue.

2. When an employee with an ongoing rehabilitation plan is laid off due to economic reasons, is he or she entitled to placement services?

Yes, the employee is entitled to services. At this point, the qualified rehabilitation consultant would propose an R-3 Rehabilitation Plan Amendment form to reflect a change in the vocational plan. The services listed in number 18 would include job-seeking skills training, job-placement services, etc.

Retraining

1. What are the Poole factors the Workers' Compensation Court of Appeals applied to retraining plans and are currently used when considering approvals?

The Poole factors are found in the case of Poole v. Farmstead Foods, Inc., 42 W.C.D. 970, 978 (WCCA 1989). In that case, the Workers' Compensation Court of Appeals identified factors to be considered in determining whether retraining is appropriate. The factors include:

  1. the reasonableness of retraining as compared to returning to work with the employer or other job-placement activities;

  2. the likelihood the employee has the ability and interest to succeed in a formal course of study in a school;

  3. whether retraining is likely to result in reasonably attainable employment; and

  4. whether retraining is likely to produce an economic status as close as possible to that which the employee would have enjoyed without disability.

2. If a retraining plan has been signed by all parties (the employee, insurer and qualified rehabilitation consultant) will the department automatically sign and approve the plan?

No, the approval will not be automatic. See Minnesota Rules 5220.0750, subp. 5.

Rehabilitation plan disputes

1. When a qualified rehabilitation consultant (QRC) is sent a notice for a nonrehabilitation conference, should the QRC attend?

If an attorney or adjuster wants a rehabilitation provider to attend a hearing of any type and is willing to pay the provider's hourly fee, the provider should plan to attend. If the parties see no reason for a rehabilitation provider to attend, there is probably no reason to do so. If possible, a rehabilitation provider should be available by phone during the time, in case an issue arises for which the provider would have valuable input.

More information

If you don't see your question answered here or want more information for rehabilitation providers, contact DLI's Workers' Compensation Help Desk at helpdesk.dli@state.mn.us, 651-284-5005 (press 3) or 800-342-5354 (press 3).