Form LS-204, the Attending Physician’s Supplementary Report, is the official medical progress form physicians file with the U.S. Department of Labor’s Office of Workers’ Compensation Programs to update injury status, treatment, and work capacity for injured workers covered by the Longshore and Harbor Workers’ Compensation Act (LHWCA). You fill it out by entering the worker’s identifying data, the OWCP case number, the diagnosis, the treatment plan, the work-status opinion, and the physician’s signed certification, then submit it to the appropriate OWCP district office within the time limits set by 20 C.F.R. § 702.413.
The problem LS-204 solves is the information gap between a treating doctor and the claims examiner who must decide whether to start, continue, suspend, or terminate compensation under 33 U.S.C. § 907. Without a current LS-204, the district director cannot verify ongoing disability, and benefits can stall under 33 U.S.C. § 914(d), which lets the carrier suspend payments when medical proof of continuing disability is missing. The form also feeds the carrier’s obligation to pay medical bills under 33 U.S.C. § 907(d) and the employee’s duty to submit to examination under section 7(d)(4).
According to the DOL’s FY 2024 Longshore statistics, more than 25,000 active LHWCA cases moved through OWCP district offices last fiscal year, and a significant share were delayed because attending physicians sent incomplete or late LS-204 reports. That single paperwork breakdown is the leading administrative reason indemnity checks pause.
Here is what you will learn in this guide:
- 🩺 The exact box-by-box meaning of every field on Form LS-204 and how to enter the right data
- ⚖️ How LHWCA, the Defense Base Act, OCSLA, and NFIA all rely on the same LS-204 mechanics
- 📅 The filing deadlines, district-office routing rules, and electronic submission options through SEAPortal
- 🚫 The seven most damaging mistakes that suspend benefits, draw section 30(e) penalties, or trigger a Form LS-208 controversion
- 💰 How LS-204 interacts with LS-1, LS-202, LS-203, LS-206, and LS-208 inside the broader Longshore claim lifecycle
What Form LS-204 Is and Who Must File It
Form LS-204 is a one-page OWCP-approved supplementary medical report used to keep a Longshore claim file current after the initial LS-1 Request for Examination and Treatment has already opened the medical record. The form is published by the Division of Federal Employees’, Longshore and Harbor Workers’ Compensation and carries an OMB control number that must be visible at the top of any version you submit. The attending physician, not the claimant and not the employer, is the party who signs and certifies the report.
The duty to file flows from 20 C.F.R. § 702.422, which requires the physician of record to furnish reports of examination and treatment whenever the district director requests them, and from the carrier’s parallel duty to obtain medical evidence supporting any payment of compensation. A physician who refuses to file can have fees suspended under section 7(d)(4), and the worker can be referred for a second opinion under section 7(e). The form also satisfies the recordkeeping rule in 20 C.F.R. § 702.424.
The plain-English version is simple: when a hurt longshore worker keeps seeing the doctor, the doctor must keep the government posted. The consequence of ignoring that duty is that the carrier can stop paying weekly checks, the doctor can lose the right to bill OWCP, and the claim can be controverted on Form LS-207. A real example: Maria Lopez, a container-terminal clerk in Long Beach, lost three weeks of temporary total disability payments because her orthopedist’s office sent the LS-204 to the employer’s HR department instead of the OWCP San Francisco district office. The common misconception is that emailing the carrier is enough — it is not, because the regulation requires the report to reach the district director.
Who Counts as the “Attending Physician”
The attending physician is the licensed practitioner the injured worker chose under the free-choice rule in 33 U.S.C. § 907(b) after the employer’s initial referral. That choice, once made and approved by the district director, locks in who must sign the LS-204. Physician assistants and nurse practitioners may prepare the form, but the supervising physician must sign it for OWCP to accept it as evidence of disability.
A switch in physicians requires prior written approval from the district director under 20 C.F.R. § 702.406, and unauthorized switches make the new doctor’s LS-204 inadmissible. Dr. Henry Park, an occupational medicine specialist in Houston, learned this when his LS-204 reports for a Defense Base Act welder were rejected because the worker never filed Form LS-205 to change physicians. The consequence is unpaid medical bills and a benefits gap.
Who the Form Is Filed About
The form is filed about a worker whose injury falls under LHWCA itself or under one of its four extension acts: the Defense Base Act, the Outer Continental Shelf Lands Act, the Nonappropriated Fund Instrumentalities Act, and the District of Columbia Workmen’s Compensation Act for pre-1982 injuries. The same LS-204 form is used across all five jurisdictions because OWCP administers them through a single Longshore claims system.
The injured worker must already have a Longshore case number assigned by an OWCP district office. Without that case number, the LS-204 cannot be matched to a file and will sit in the unidentified-mail queue. Marcus Reed, a civilian contractor injured in Bahrain under DBA, waited 47 days for his disability check because his pulmonologist filed an LS-204 with no case number.
Statutory and Regulatory Framework
LS-204 sits inside a tightly woven federal scheme. The statute is 33 U.S.C. §§ 901–950, the regulations are 20 C.F.R. Part 702, and the procedural guidance is the OWCP Longshore Procedure Manual. Each layer answers a different question — the statute creates the right, the regulation creates the form, and the manual creates the workflow.
The plain-English explanation is that Congress wrote the law, the Secretary of Labor wrote the rules, and OWCP wrote the playbook. The consequence of ignoring any layer is that a claim can be denied on the merits, controverted procedurally, or simply lost in the mail. Attorney Janelle Vasquez in New Orleans built her practice on catching procedural defects in LS-204 filings that opposing counsel missed. The misconception is that LHWCA and state workers’ comp are interchangeable — they are not, and a state-form medical report cannot replace LS-204.
33 U.S.C. § 907 — Medical Services and Supplies
Section 907 is the medical-benefits engine of the Longshore Act. It guarantees lifetime medical care for the work injury, sets the free-choice rule for physicians, and authorizes the Secretary to require reports in any form she prescribes. LS-204 is one of those prescribed forms.
The consequence of section 907 noncompliance is severe. A physician who fails to file required reports forfeits the right to be paid, and the carrier that pays a non-reporting physician can be ordered to recoup. Dr. Lillian Chen, a Seattle hand surgeon, lost \$18,400 in fees because she billed without filing six consecutive LS-204 reports during a year-long carpal-tunnel recovery.
20 C.F.R. § 702.413 — Reports of Earnings and Medical Status
This regulation gives the district director authority to demand updated medical reports at any reasonable interval and identifies LS-204 as the supplementary vehicle. The rule is paired with 20 C.F.R. § 702.414, which sets the content requirements: history, diagnosis, treatment, prognosis, and work capacity.
The consequence of skipping any required content is that OWCP treats the report as no report at all. Patient Devon Williams, a tugboat deckhand, had his temporary partial disability checks suspended because the LS-204 his physician filed left the work-capacity box blank. The misconception is that “see attached notes” satisfies the regulation — it does not, because each box must contain a discrete answer.
Step-by-Step: How to Fill Out Form LS-204
The form is organized into five logical zones: claimant identification, case identification, medical findings, work-capacity opinion, and physician certification. Walk through each zone in order, and never leave a box blank. If a field does not apply, write N/A, because empty fields trigger return-mail rejections under the OWCP forms processing protocol.
The plain-English approach is to treat the form like a checklist where every line is a yes-or-no gate. The consequence of skipping a gate is rejection and lost time. Office manager Priya Patel in a Norfolk orthopedic clinic cut her LS-204 rejection rate from 22% to under 3% by laminating a one-page completion checklist.
Zone 1 — Claimant Identification
Enter the injured worker’s full legal name exactly as it appears on the LS-1, the date of injury, the date of birth, and the Social Security number. Mismatches between LS-204 and LS-1 cause OWCP’s case-matching software to reject the form. Always pull the data from the LS-1 of record, not from the patient’s intake sheet.
The consequence of a mismatch is a 10-to-30-day delay while the district office requests a corrected form. Claimant Robert Tanaka, a Honolulu stevedore, lost 21 days of wage replacement because his physician used a nickname instead of his legal first name. The misconception is that small typos are harmless — they are not, because automated matching is unforgiving.
Zone 2 — Case Identification and Employer Data
Enter the seven-digit OWCP case number, the carrier or self-insured employer name, the carrier’s claim number, and the district office of jurisdiction. The 12 OWCP district offices each handle defined geography, and routing the LS-204 to the wrong district adds two to four weeks. Use the district office locator before mailing.
The consequence of wrong-district routing is that the form moves through internal mail before reaching the right examiner. Nurse case manager Sandra Okafor in Jacksonville keeps a wall map of OWCP districts to prevent this exact error. The misconception is that the worker’s home address controls — it does not, because jurisdiction usually follows the situs of injury.
Zone 3 — Medical Findings
Record the current diagnosis using ICD-10 codes, the objective findings from the most recent examination, the diagnostic tests performed, and the response to treatment to date. Be specific: “lumbar strain” is weaker than “L4-L5 disc protrusion with right S1 radiculopathy confirmed by MRI dated 03/12/2026.” OWCP claims examiners weight specific findings far more heavily than generic ones.
The consequence of vague findings is that the carrier may controvert the claim on Form LS-207 for lack of medical evidence. Dr. Aaron Goldberg, a Mobile-area neurologist, lost a controversion hearing because his LS-204 used the phrase “back pain” without imaging support. The misconception is that the chart note is enough — it is not, because the LS-204 itself must contain the findings.
Zone 4 — Treatment Plan and Prognosis
State the planned treatment, the expected duration, the date of maximum medical improvement (MMI) if reached, any permanent impairment rating using the AMA Guides 6th Edition, and any referrals to specialists. MMI is a legal trigger that converts temporary disability to permanent disability under 33 U.S.C. § 908, so dating it carefully matters.
The consequence of an unsupported MMI date is overpayment recoupment under 20 C.F.R. § 702.225. Carrier adjuster Tom Brennan recouped \$42,000 from a worker after a physician reversed an MMI date on a later LS-204. The misconception is that MMI ends medical benefits — it does not, because section 907 medical care continues for life.
Zone 5 — Work-Capacity Opinion
Mark whether the worker is totally disabled, partially disabled, or able to return to full duty, and list any restrictions in plain-language terms (lifting limits, standing limits, climbing limits, exposure limits). This zone drives the weekly indemnity check. Use specific pound-and-hour numbers, not vague phrases like “light duty.”
The consequence of vague restrictions is that the employer cannot offer suitable alternative employment under 33 U.S.C. § 908(e), which can either inflate or deflate the worker’s benefits depending on direction. Vocational counselor Elaine Foster in Galveston tells doctors to write “lift 20 lbs occasionally, 10 lbs frequently, no overhead reaching, 6-hour workday.” The misconception is that the doctor decides the job — the doctor decides the medical limits, and the employer matches a job to those limits.
Zone 6 — Physician Certification and Signature
Sign and date the form, print the physician’s name, list the medical license number, the state of licensure, the National Provider Identifier (NPI), the office address, and the telephone number. An electronic signature is acceptable if it complies with 21 C.F.R. Part 11 standards and the OWCP electronic submission rules.
The consequence of a missing signature is automatic rejection. Billing supervisor Karen Holloway at a New Bedford clinic now requires every LS-204 to clear a “signature, date, NPI” checkpoint before scanning. The misconception is that a stamped signature works for all OWCP forms — it does not, because OWCP requires either a wet ink or compliant electronic signature on LS-204.
Filing, Deadlines, and Submission Channels
OWCP accepts LS-204 by mail, by fax, or through the SEAPortal electronic submission system launched in 2018 and expanded in 2024. The deadline is “within a reasonable time” under section 702.413, which OWCP interprets as 14 days from the examination in active-treatment cases and 30 days in maintenance cases.
The consequence of late filing is suspension of payments under section 14(d) and possible section 30(e) penalties for the employer if the lateness causes a controversion delay. Self-insured employer Pacific Rim Stevedoring paid \$6,200 in section 14(e) additional compensation because a contracted clinic filed three LS-204 reports late. The misconception is that the doctor controls the deadline — both the doctor and the employer share exposure.
Mail and Fax Routing
Each district office has a unique mailing address and fax line, listed on the OWCP contacts page. Always include the OWCP case number on the cover sheet and on every page. Faxed forms must be legible at 200 dpi or higher.
The consequence of an illegible fax is that the form is treated as not received. Receptionist Carla Diaz in a San Pedro clinic now scans every LS-204 to PDF before faxing to confirm legibility. The misconception is that a confirmation page proves receipt — it proves transmission, not legibility.
SEAPortal Electronic Submission
SEAPortal lets registered providers upload LS-204 directly into the OWCP case file with same-day docketing. Registration requires an NPI, a Login.gov account, and a one-time identity-proofing step. Once registered, providers can also pull payment-status information.
The consequence of skipping SEAPortal in 2026 is slower payment, because OWCP’s electronic adjudication queue runs ahead of the paper queue. Practice administrator Jose Ramirez moved a 14-physician occupational clinic to SEAPortal and cut average reimbursement time from 38 days to 11. The misconception is that SEAPortal is optional forever — OWCP has signaled a future mandatory transition for high-volume providers.
Three Common LS-204 Scenarios
Real cases follow patterns. The three most common LS-204 fact patterns are the active-treatment update, the MMI/permanency report, and the return-to-work release. Each one has a different downstream effect on the claim.
| Filing Situation | Downstream Effect on the Claim |
|---|---|
| Active-treatment update at week 6 of physical therapy after a rotator-cuff tear | Carrier continues temporary total disability payments without controversion |
| MMI report with 12% upper-extremity impairment under AMA Guides 6th Edition | Claim converts to permanent partial disability under 33 U.S.C. § 908(c) and a scheduled award is calculated |
| Full-duty release with no restrictions after a lumbar strain resolves | Indemnity stops the day after the release date, but section 907 medical benefits remain open for life |
| Common Filing Error | Consequence Under LHWCA |
|---|---|
| Missing physician signature on the LS-204 | OWCP rejects the report and the carrier may suspend payments under section 14(d) |
| Wrong district office on the routing envelope | 2-to-4-week internal forwarding delay and possible duplicate-filing confusion |
| Vague work restrictions written as “light duty” | Employer cannot identify suitable alternative employment, leading to disputes under section 8(e) |
| Strategic Filing Choice | Practical Payoff |
|---|---|
| Using SEAPortal instead of fax | Same-day docketing and faster reimbursement |
| Including objective imaging findings in Zone 3 | Reduces controversion risk and strengthens the LHWCA medical record |
| Stating specific pound-and-hour restrictions in Zone 5 | Enables precise wage-earning-capacity calculations under section 8(h) |
Mistakes to Avoid When Filing LS-204
Even seasoned offices stumble on LS-204. Below are the seven mistakes that cause the most damage to claims and reimbursements. Each one carries a real, traceable consequence under the statute or regulation.
- Leaving the work-capacity box blank, which causes OWCP to treat the report as no report and the carrier to suspend wage replacement under section 14(d).
- Filing without an OWCP case number, which sends the form to the unidentified-mail queue and adds 30-plus days of delay.
- Using state workers’ compensation form fields instead of the federal LS-204 layout, which violates 20 C.F.R. § 702.414 and forces a refile.
- Omitting the NPI or license number, which prevents OWCP from validating the provider in the Provider Enrollment system and blocks payment.
- Backdating MMI to match a litigation strategy, which can trigger fraud referrals under 18 U.S.C. § 1920 and physician decertification.
- Faxing to a closed district office line without confirming the current number on the OWCP contacts page, which loses the report entirely.
- Failing to attach diagnostic imaging or test results referenced in Zone 3, which weakens the medical record and invites a section 7(e) second opinion examination.
Named Examples Across Jurisdictions
Federal Longshore claims play out across very different settings. These three named scenarios show how LS-204 mechanics translate from a domestic shipyard to an overseas Defense Base Act site to an offshore platform.
Marcus Reed, a civilian electrician injured by an arc flash in Kuwait under the Defense Base Act, files LS-204 reports through his Houston-based burn specialist. Because DBA piggybacks on LHWCA, the LS-204 routes to the OWCP New York district office, which handles overseas DBA claims. Without timely LS-204 filings, his AIG-administered carrier suspends weekly checks under section 14(d).
Maria Lopez, a Long Beach container clerk with a herniated disc, files LS-204 reports every six weeks during conservative care. When her surgeon recommends fusion under 33 U.S.C. § 907(d), the LS-204 must include the proposed CPT code so the carrier can authorize the procedure. The San Francisco district office adjudicates her claim.
Captain David Olsen, an OCSLA-covered platform worker injured in the Gulf of Mexico, files LS-204 reports through a Lafayette occupational clinic. OCSLA jurisdiction routes to the New Orleans district office. His MMI report converts the claim to permanent partial disability under section 8(c)(13) for hearing loss, calculated using the AMA Guides 6th Edition.
How LS-204 Compares to Other Longshore Forms
LS-204 is one form in a family of OWCP Longshore documents. Knowing how it relates to its siblings prevents wasted filings and missed deadlines. The full forms catalog is available on the OWCP Longshore forms page.
| Form | Primary Purpose |
|---|---|
| LS-1 | Employer’s request for examination and treatment that opens the medical record |
| LS-202 | Employer’s first report of injury filed within 10 days under section 30(a) |
| LS-203 | Employee’s claim for compensation filed within one year under section 13 |
| LS-204 | Attending physician’s supplementary report of medical status and work capacity |
| LS-206 | Payment of compensation without award notice from the carrier |
| LS-208 | Notice of final payment or suspension of compensation |
Do’s and Don’ts for LS-204
Practical habits separate clean LS-204 filings from rejected ones. The list below reflects guidance from the OWCP Longshore Procedure Manual and decades of district-office practice.
Do’s
- Do verify the OWCP case number against the LS-1 before signing, because mismatches cause automatic rejection.
- Do file within 14 days of each examination in active cases, because section 14(d) suspension follows late reports.
- Do include ICD-10 codes and CPT codes, because OWCP claims examiners use them to validate medical necessity.
- Do route to the correct district office using the OWCP contacts page, because misrouting costs weeks.
- Do retain a copy for at least five years under 20 C.F.R. § 702.424, because audit demands can come years later.
Don’ts
- Don’t substitute a state workers’ comp form, because LHWCA preempts and the substitution is invalid under section 702.414.
- Don’t leave any box blank, because empty fields trigger return-mail rejection.
- Don’t backdate MMI, because fraud exposure under 18 U.S.C. § 1920 is real.
- Don’t fax without confirming the current district fax number, because closed lines lose reports entirely.
- Don’t let non-physician staff sign the certification, because only the licensed attending physician’s signature is valid.
Pros and Cons of Electronic LS-204 Filing
Switching from paper to SEAPortal is a strategic decision that touches workflow, reimbursement timing, and audit readiness. Here is the honest tradeoff.
Pros
- Same-day docketing in the OWCP case file, because the upload bypasses internal mailroom routing.
- Faster reimbursement under the OWCP medical bill processing system, because electronic forms feed adjudication queues first.
- Built-in field validation that catches missing data before submission, because the portal flags empty required fields.
- Permanent timestamp evidence, because section 30(e) penalty disputes turn on proof of filing date.
- Reduced supply costs, because paper, postage, and fax lines disappear from the budget.
Cons
- Identity-proofing setup takes one to three weeks, because Login.gov verification is not instant.
- Requires NPI registration through the OWCP Provider Enrollment portal, which adds an upfront administrative step.
- Some older OWCP-compatible electronic medical record systems do not yet integrate, requiring manual upload.
- Outages occasionally occur, because any federal portal experiences scheduled maintenance windows.
- Staff retraining costs, because billing teams accustomed to paper must learn the upload workflow.
Court Rulings That Shape LS-204 Practice
Federal courts have repeatedly weighed in on the evidentiary weight of attending-physician reports. Director, OWCP v. Greenwich Collieries, 512 U.S. 267 (1994), eliminated the “true doubt” rule, placing the burden of persuasion on the party with the burden of proof, which makes the LS-204’s specificity and completeness strategically critical. A vague LS-204 hurts the side that needs it most.
In Potomac Electric Power Co. v. Director, OWCP, 449 U.S. 268 (1980), the Supreme Court held that scheduled awards under section 8(c) are exclusive when the injury fits the schedule, which gives the LS-204’s MMI date and impairment rating outsized financial impact. The doctor’s words on Zone 4 of LS-204 can shift a six-figure award.
Metropolitan Stevedore Co. v. Rambo, 521 U.S. 121 (1997), confirmed that wage-earning capacity can be modified later under section 22, and the modification almost always rests on a new LS-204 documenting changed medical status. The form is therefore not a one-time event but a living document that can reopen a closed claim.
Frequently Asked Questions
Is Form LS-204 the same as a state workers’ compensation medical report?
No. LS-204 is a federal form unique to the LHWCA and its extension acts, and a state workers’ comp medical report cannot substitute for it under 20 C.F.R. § 702.414, which controls federal Longshore filings.
Does the injured worker fill out Form LS-204?
No. The attending physician of record fills out and signs LS-204, although clinic staff may prepare drafts and the physician must personally certify the completed form before submission to OWCP.
Is there a filing fee for LS-204?
No. OWCP charges no fee to file LS-204, and physicians are reimbursed for the report itself under the OWCP Longshore medical fee schedule when properly coded and submitted.
Can LS-204 be filed electronically in 2026?
Yes. Registered providers file LS-204 through SEAPortal, which provides same-day docketing, field validation, and permanent timestamp evidence that paper filings cannot match.
Will benefits stop if LS-204 is filed late?
Yes. The carrier may suspend wage replacement under section 14(d) when no current LS-204 supports continuing disability, and resumption requires a fresh, compliant report routed to the correct district office.
Does LS-204 apply to Defense Base Act claims overseas?
Yes. The Defense Base Act incorporates LHWCA procedures, so LS-204 applies to civilian contractors injured abroad and routes to the OWCP New York district office for adjudication.
Is a stamped physician signature acceptable on LS-204?
No. OWCP requires either a wet-ink signature or a 21 C.F.R. Part 11-compliant electronic signature, and stamped signatures are routinely rejected by district office intake clerks.
Can a chiropractor sign LS-204 as the attending physician?
Yes. A chiropractor may sign LS-204 within the scope of section 907’s definition of physician, but only for treatment of subluxation of the spine demonstrated by X-ray, which is a narrower scope than for medical doctors.
Does filing LS-204 waive the worker’s right to a formal hearing?
No. LS-204 is purely a medical evidence document, and the worker retains the full right to request a formal hearing before an administrative law judge under 33 U.S.C. § 919 regardless of how many LS-204 reports have been filed.
Will an LS-204 reopen a claim closed years ago?
Yes. Under section 22 a claim may be modified within one year of the last payment of compensation, and a new LS-204 documenting changed medical status is the standard vehicle for triggering that modification request.
Does the employer get a copy of LS-204?
Yes. OWCP serves the LS-204 on the employer or its carrier, and the worker’s representative also receives a copy, because all parties need the medical record to evaluate ongoing benefit obligations.
Is there a penalty on the physician for filing a false LS-204?
Yes. Knowingly filing a false LS-204 exposes the physician to criminal penalties under 18 U.S.C. § 1920, civil penalties under the False Claims Act, and decertification from the OWCP provider list.
Related reading
- How to Fill Out DOL Form WH-384 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-1 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-265 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-276 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-33 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-570 (w/Examples) + FAQs
- How to Fill Out DOL Form OWCP-16 (w/Examples) + FAQs