Tips for billing success: Signature requirement for Colorado DOWC

All medical records, including the WC164 forms, should be signed by the rendering provider.
Back to Knowledge Center

All medical records, including the WC164 forms, should be signed by the rendering provider. Electronic or handwritten signatures are accepted. The author must authenticate medical record entries for services that are ordered and provided. CMS1500 forms will need to have the rendering provider’s name and credentials listed in Box 31.

All Colorado Workers’ Compensation claims must have an authorized treating physician (ATP) available in person or by telephone when the services are provided by a Physician’s Assistant (PA) or a Nurse Practitioner (NP). The ATP must countersign the patient records and WC164 form. The ATP’s signature will serve as certification that all the requirements detailed in Rule 16 have been met. See below for further information.

Regarding the use of PAs and NPs in Colorado Workers’ Compensation claims

  • All Colorado Workers’ Compensation claims shall have an ATP who is responsible for all services rendered to an injured worker by any PA or NP.
  • The ATP must be available in person or by telephone to furnish assistance or direction to the PA or NP while services are being provided to an injured worker.
  • The service must be within the scope of the PA’s or NP’s practice and comply with all applicable provisions of the Colorado Medical Practice Act or the Colorado Nurse Practice Act as well as all applicable rules promulgated by the Colorado Medical Board or the Colorado Board of Nursing.
  • For services performed by a PA or an NP, the ATP must countersign patient records related to:
  • The injured worker’s inability to work as a result of the claimed work injury or disease and
  • The injured worker’s ability to return to regular or modified employment.
  • The ATP must also countersign the WC164. The physician’s signature shall serve as certification that all of this rule’s requirements have been met.
  • The ATP must evaluate the injured worker within the first three visits to the physician’s office.


As of 2018, services provided by a PA or NP that meet the “incident to” criteria will no longer be eligible for consideration at 100 percent of the fee schedule. According to Colorado DOWC Rule 18, PAs and NPs will be paid at 85% of the fee schedule, excluding the following exceptions that will be paid at 100 percent:

  • Services provided in a non-Metropolitan Statistical Area
  • Services provided in a Health Professional Shortage Area
  • Level 1 accredited Physician’s Assistants and Nurse Practitioners (as of August 2, 2019)


Colorado Division of Workers’ Compensation Rules

Adapting your business for COVID-19 impacts