Workers’ Compensation Roundup: What Changed in August–September 2025 (Nationwide)

At Jeffrey Glassman Injury Lawyers, we follow workers’ compensation updates daily because small rule changes can determine how quickly an injured worker receives medical care, how income benefits are calculated, and whether a settlement will truly cover future treatment. This nationwide briefing highlights the most significant developments for August and September 2025, and explains the actions that injured workers, employers, medical providers, and claims professionals can take now.

Why these months matter

Late summer is when several agencies lock in decisions that ripple into fall renewals, holiday-season settlements, and next year’s budgets. In the last few weeks, federal guidance has tightened expectations around Medicare Set-Asides in compensation cases, multiple states have adjusted billing and documentation rules, and rate or guideline decisions have been made that will influence both premiums and medical utilization in the months ahead. If you are an injured worker navigating a claim or a business planning for 2026 costs, the changes below are not academic; they are practical and immediate.

National changes to have on your checklist

CMS eliminates $0 Medicare Set-Asides

CMS updated the Workers’ Compensation Medicare Set-Aside (WCMSA) Reference Guide this summer, and the headline is straightforward: submissions on or after July 17, 2025, can no longer be for $0. That does not prevent parties from settling a claim without a formal MSA review in narrow circumstances; however, it does place the burden on providing adequate documentation. For any settlement that implicates Medicare’s interests, we now expect a non-zero allocation or a robust medical narrative proving why no future Medicare-covered care is reasonably anticipated.

What we are doing for clients: We build treatment roadmaps with treating physicians before settlement talks, especially for orthopedic, chronic pain, and head injury cases. We also review pharmacy histories, and durable medical equipment needs to ensure future-care estimates are realistic and defensible.

Federal OWCP authorization and billing adjustments

For federal workers’ compensation claims, the Office of Workers’ Compensation Programs has tightened the procedure codes submitted with medical authorization requests, effective August 9, 2025. Clinics and hospitals that treat federal employees should align their templates with the new portal requirements and confirm that the rendering of NPIs, service locations, and codes matches exactly. Even minor mismatches can trigger delays or denials that push back care for injured workers.

What we do for clients: When a federal employee retains us, we coordinate directly with their providers to ensure that authorizations and bills accurately reflect the correct codes and identifiers. That reduces avoidable disputes, keeps treatment on schedule, and shortens claim duration.

Medical cost watch: Medicare fee schedules as a signal

Analysts have highlighted how the 2025 Medicare fee schedule updates can impact workers’ compensation costs, particularly in states that peg or reference Medicare methodologies. While workers’ comp is a separate system, changes to relative values, site-of-service differentials, and DMEPOS pricing often echo across comp networks. Expect more attention on ambulatory surgery center services, therapy utilization, and high-cost specialty supplies as carriers model 2026.

What we do for clients: We monitor fee schedule shifts and identify billing challenges when providers are underpaid or when carriers misapply Medicare analogs to comp-specific services. On the defense side of negotiations, we distinguish between genuine cost controls and improper denials that delay medically necessary care.

State snapshots, you will feel this fall

California: new policy year anchor and MTUS updates

California’s Insurance Commissioner issued an advisory pure premium rate decision effective September 1, 2025. Advisory rates do not dictate every employer’s manual premium, but they influence carrier filings and the tone of renewals statewide. At the same time, the Division of Workers’ Compensation set a public hearing on September 26, 2025, to adopt updates to the Medical Treatment Utilization Schedule. Those proposed chapters include refinements for body-part-specific conditions and head injuries, which can affect utilization review, prior authorization, and dispute resolution through the end of the year.

Action steps:

Employers and brokers: Review class codes, experience mods, and schedule credits with your carrier as September policies renew.
Clinics and UR teams: Update prior authorization templates to match the pending MTUS chapters and prepare clinician education so notes reflect guideline criteria on day one.
Injured workers: If your treatment was repeatedly delayed on guideline grounds, talk to us about how updated MTUS language might change the review outcome.

New York: e-billing mandate now in force

As of August 1, 2025, New York requires all workers’ comp CMS-1500 bills to be submitted electronically through Board-approved partners. Paper submissions risk nonpayment and can stall treatment plans that depend on timely reimbursement. Carriers and TPAs have also standardized explanation codes for rejecting noncompliant paper bills.

Action steps:

Providers: Confirm that your clearinghouse or software partner is Board-approved; audit the front desk and revenue cycle teams to ensure that no paper is slipping through.
Injured workers: Ask your doctor how they submit comp bills. If they are still mailing paper, that could delay your care; we can help get them compliant or find an in-network alternative.

Texas: data-driven oversight and rule alignment

Texas continues to publish detailed research on benefits and outcomes. A 2025 Income Benefits Report was released in late August, providing a fresh look at wage replacement across various injury types and wage bands. The Division’s Research and Evaluation Group also unveiled its proposed FY2026 research agenda, which includes projects on medical cost trends, return-to-work outcomes, and network performance. Separately, the Texas Register posted a proposal in late August to align a supplemental income benefits rule section with statutory work-search requirements, with public comments due in early October.

Action steps:

Claimants: If you are pursuing or receiving supplemental income benefits, keep meticulous work-search documentation as rules evolve.
Employers: Submit comments on research priorities that affect your program, including network performance metrics that drive medical and indemnity outcomes.

Washington: more substantial return-to-work incentives and higher average rates

For injury dates on or after January 1, 2025, Washington expanded the Stay-at-Work program and increased the maximum wage reimbursements per claim to $25,000. The state also implemented an average premium increase for 2025, a modest uptick attributed to medical and benefit cost trends. The policy signal is clear: Washington wants employers to invest in modified duty, ergonomic accommodations, and transitional roles that facilitate a safe return to work.

Action steps:

Employers: Do not leave money on the table. Budget for transitional roles and pair them with ergonomic improvements that match medical restrictions.
Injured workers: Consider modified duty if your doctor clears it. Well-designed light duty can shorten disability and protect wage loss while you recover.

Massachusetts: rate proposal rejected, assessments updated

In the spring, Massachusetts declined a proposed 7.1 percent increase in workers’ compensation rates for policies effective July 1, 2025. That decision keeps employers on 2024 rate levels through the back half of this year, while updated assessments took effect in July. For injured workers, the headline is stability; for employers, it is a manageable premium environment as we head into budget season.

Action steps:

Employers: Use the breathing room to invest in safety programs and claims hygiene.
Injured workers: If carrier financial pressures were used to justify delays, rate stability undercuts that excuse.

Labor developments with comp implications

Ride-hail bargaining framework in California

State leaders announced a late-August agreement that would allow ride-hail drivers to unionize and bargain collectively while preserving their contractor status under Proposition 22. Details will become clearer as the final bill language is published and implemented. The agreement also anticipates adjustments to specific insurance requirements to avoid passing excessive costs to riders.

Why it matters for comp: Even if drivers remain outside traditional workers’ compensation as employees, a bargaining framework can elevate safety standards, vehicle inspection protocols, deactivation review, and access to alternative injury protections. Those improvements can reduce the frequency of crashes and injuries, which ultimately affect the risk environment on the same roads where our clients drive and work.

Staffing strain and injury spikes

An investigative story published today highlighted a familiar reality in healthcare and other 24/7 operations: chronic understaffing and extended shifts are correlated with higher injury rates. We continue to see this link in claims across various industries, including hospitals, long-term care, warehousing, and logistics. When staffing ratios are inadequate, lifting injuries, slips, needle sticks, and burnout-related accidents increase. That means more time away from work, more disputes about causation, and higher medical spend.

What we recommend: If you manage a facility, revisit shift-length policies, float pools, and safety refreshers. If you are an injured worker, document overtime mandates and task loads in real-time; these details help prove causation and disability and can be pivotal in hearings and settlement talks.

Practical playbooks for each audience

Injured workers

Plan for future care early: If you are a Medicare beneficiary or will become one within the next 30 months, ensure your treating doctor writes a clear treatment plan that outlines expected services and their durations. That plan drives realistic settlement numbers after the new MSA posture.
In New York, protect your timeline: Ask every provider whether they submit bills electronically through an approved partner. If not, payment delays can cascade into treatment gaps.
In Texas, over-document work searches: Keep calendars, screenshots, applications, and rejection emails. It is easier to meet evolving standards if you establish a strong record from day one.
In Washington, consider modified duty: If your doctor approves, take the opportunity. Transitional work can shorten recovery time and stabilize income.

Employers and claims professionals

Refresh settlement playbooks: Remove any default $0 MSA language from templates, require future-care narratives in every settlement package, and set internal guardrails for pharmacy and DME estimates.
New York compliance: Map every provider in your network to a Board-approved e-billing partner, and standardize your explanation codes for paper denials to avoid unnecessary friction.
California readiness: For September renewals, review classification assignments, loss trends, and experience mods. Prebrief UR teams and panel QME coordinators on pending MTUS updates to prevent cases from stalling due to documentation gaps.
Washington return-to-work: Use the enhanced reimbursement ceiling to fund transitional jobs, equipment, and training. The first weeks after an injury are crucial; make light duty a reality, not just a theory.
Texas engagement: Comment on research agendas and rule changes that affect SIBs and network oversight; these public inputs shape the metrics that will judge your program next year.

Medical providers

Authorization discipline: Align OWCP requests to the new code limits; double-check rendering NPI, place of service, and diagnosis linkages.
Documentation that moves UR: In California and elsewhere, apply guideline language explicitly in your notes. State the rationale, the objective findings, and the step-down plan.
E-billing hygiene: In New York, ensure front-desk and billing staff are trained on electronic submission workflows. In other states, check whether payers are updating clearinghouse specs ahead of fee schedule changes.

How we are helping right now

We are a claim-side law firm that believes good outcomes require both policy fluency and hands-on advocacy. Our team calibrates settlement strategies to the new MSA rules, we coordinate with physicians to build precise future-care narratives, and we push carriers to honor treatment guidelines as they are actually written, not as they wish they were. When e-billing or authorization glitches create roadblocks, we work with providers to resolve them, allowing our clients to receive the care they need without unnecessary interruptions. And when a return-to-work offer is made, we pressure-test it against medical restrictions and wage-replacement realities so our client is not forced into unsafe duties.

If your claim feels stuck, underpaid, or rushed toward a settlement that ignores future medical needs, we want to hear from you. At Jeffrey Glassman Injury Lawyers, we handle every stage of the process, including filing claims, challenging denials, preparing for independent medical exams, litigating at hearings and appeals, and negotiating settlements that respect both present and future care needs.