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Electronic Policy Submission Test Requirements

Each data provider – either an insurer or an authorized third-party entity (TPE) – must submit a test file for approval before beginning to report production policy files electronically. Please review the guidelines below and then contact the WCIRB Data Submission Analysts at [email protected] to arrange the test. Please note that before a TPE can submit policy data on behalf of an insurer, the insurer must enter into an indemnification agreement with the WCIRB. View the Using Third Parties page to learn more.

The purpose of the testing is to check for WCPOLS format compliance and preprocessing errors and to ensure that the policy data reported electronically matches the hard copy policy. 

Testing is necessary under the following conditions:

  • The insurer or authorized TPE plans to submit policy data for the first time.
  • The insurer or authorized TPE plans to submit a policy transaction type for the first time in California.
  • The insurer or authorized TPE plans to submit policy data for a new insurer as part of an existing insurer group.
  • An authorized TPE plans to submit policy data for a new insurer.
  • The insurer or authorized TPE transitions to a new system for entering or creating policy data submissions, including transitions to and from PEEP and proprietary systems.
  • The insurer or authorized TPE makes significant changes to its proprietary system for entering or creating policy submissions or makes any changes that could affect data quality.

Getting Started

Please take the following steps before beginning to test policy submission files:

  1. Review the California Regulations. The California Insurance Commissioner's regulations for the reporting of policy data can be found here: California Workers' Compensation Uniform Statistical Reporting Plan—1995 (Uniform Statistical Reporting Plan). 
  2. Review the reporting format specifications (WCPOLS). The specifications for electronic reporting of policy data were developed by the Workers Compensation Insurance Organizations (WCIO) and are located on the WCIO website as a part of the WCIO's SearchPoint application.

    Each policy data submission must contain an Electronic Transmittal Record (ETR). The ETR is the required first record in every submission file, and some of WCIRB Connect’s policy preprocessing edits validate fields in the ETR. The ETR begins with the value “$!+WORKCOMP+!$” and includes identifying information about the submitter of the file and its data, such as Name of Data Provider Contact, Phone Number of Data Provider Contact, and Data Provider Type Code. The WCIO’s specifications for the ETR are not part of WCPOLS. Please refer to the Electronic Transmittal Record Specifications (ETR) on the WCIO website for the ETR fields and their attributes. All fields that are required for California should be reported in the ETR.

  3. Obtain a CDX account. Insurers and authorized TPEs must transmit policy submissions to the WCIRB electronically using the Compensation Data Exchange (CDX) system, located on the CDX website. For more information, including how to set up an account, see the CDX page. Once CDX access is obtained, contact the WCIRB Data Submission Analysts at [email protected] to arrange for the setup of the insurer group in California and policy submission testing.
  4. For insurers, determine if you want to authorize a TPE to report on your behalf. For requirements relating to the use of TPEs, see the Using Third Parties section.
  5. PEEP (Policy Entry and Edit Package) System. If your company has difficulty correctly reporting policy data in WCPOLS format for California, you may consider utilizing the PEEP system. PEEP is a web-based application that provides insurers with the ability to input, validate, edit and electronically submit policy data in WCPOLS format through the CDX system to data collection organizations. Data entry staff will need to be WCPOLS tested and approved before data may be submitted using PEEP. Please contact the WCIRB at [email protected] for more details.

    Information on PEEP can also be found on the CDX website after logging in. Access to PEEP will be granted along with CDX.

  6. Review the CDX file naming conventions. Policy submission files must be named in accordance with the file naming conventions listed on the CDX page.
  7. Identify a Policy Issuing Office Contact and, if desired, a separate Policy Submission Contact. 

Policy Issuing Office Contact
The Policy Issuing Office Contact designated for each group will receive all policy audit correspondence, inspection and no coverage reports, and bulk policy correspondence. This is the default contact for all issues related to policy data reporting. An insurer group may also designate a separate Policy Data Submission Contact.

Policy Data Submission Contact (optional)
The Policy Data Submission Contact will receive all correspondence related to policy data submission files, including rejected transactions and submissions; issues with data reporting; and reports related to policy data submissions and preprocessing errors. This correspondence will be sent by email; an email address is required.


  • Designate a single Policy Data Submission Contact for your insurer group, even if multiple individuals from your group create and submit policy data files to the WCIRB.
  • Use a group email address instead of an individual’s email address so that others can respond to correspondence in the absence of the Policy Data Submission Contact (e.g.,  [email protected] instead of [email protected]).
  • Designate a secondary contact that we will copy (“cc”) on all correspondence sent to the Policy Data Submission Contact.
  • Review the CDX Online Training Videos for PEEP, which are located on CDX under Online Training or in the registered section under the Help menu.

Test Stages and Test File Requirements

There are several steps to the policy data reporting process, including general preprocessing review, hard copy policy comparison review and endorsement reporting.

All test files should be submitted via CDX and the Submission Type Code (position 64 of the ETR) must have a value of T (“test”).

Actual policy data is preferred but fictitious test data will be accepted.

Preprocessing Testing

In order to obtain approval to start reporting policies and cancellations/reinstatements electronically, a test file must pass preprocessing with no errors. The file must contain the following 20 to 25 transactions with at least two examples of each of the following transactions:

  • New Business
  • Renewals
  • Policy Replacement Due to Key Field Change
  • Cancellations
  • Reinstatements
  • AREs/Renewal Agreements/Renewal Certificates (if applicable)
  • Coverage Notices (if applicable)

Once a preprocessing file has been successfully submitted with no preprocessing errors, your company is approved to start submitting the transactions included in the file while continuing the testing process.

Hard Copy Comparison Testing

Simultaneously, either using the Preprocessing Testing file or a subsequent separate test file, your company must submit matching hard copy documents with the following test conditions:

20-25 Transaction Codes 01/02/06 (with at least one of each)
10-12 Transaction Code 05s (with a mix of types)

Included should be:

  • Names
    • Personal Names
    • Commercial Names
    • DBA Names
    • Multiple Names
  • Addresses
    • Foreign
    • C/O Addresses
  • Experience Modifications
    • X-Mod applicable at inception
    • X-Mod applicable mid-term
    • No X-Mod applicable
  • Variable Text reporting
    • A list of your company’s endorsement forms that require variable text reporting will be provided on request.
  • A sample of the following conditions (if applicable):
    • PEO Policy (more than one may be required)
    • Group Coverage Policy
    • USL&H Policy
    • Fixed or Extended Term Policy
    • Cancel and Reinstatement issued the same day

Once it has been verified that your company has successfully reported policy data electronically based on a comparison to the hard copy policy documents, the final phase of testing may begin.

Change Endorsement Reporting

During this final phase, 20 to 25 policy change endorsement transactions must be submitted in a test file with matching hard copy documents. These change endorsements may be reported as Transaction Codes 03, 08, 10, 14 and 15 depending on the type of transaction issued by your company and should contain at least two of each type of transaction intended for subsequent production reporting. The following test conditions must be included:

  • Name changes:
    • Adding a name at inception
    • Adding a name at mid-term
    • Deleting a name at inception
    • Deleting a name at mid-term
    • Changing the named insured
  • Class code changes:
    • Adding a class code
    • Deleting a class code
  • Experience Modification changes:
    • Adding an experience modification at inception
    • Adding a mid-term experience modification
    • Deleting an experience modification
  •  Address changes:
    • Changing the mailing address
    • Adding a location
    • Deleting a location
  • Forms:
    •  Adding a form
    • Deleting a form
  • Transaction Code 15:
    • Adding California
    • Deleting California
  • Variable Text Record:
    • Changing variable text (if applicable)

Once it has been verified that your company has successfully reported the above change conditions, approval for electronic reporting of Change Endorsements will be granted.