Washington’s final bill report for SHB 2405, Chapter 220, Laws of 2026 gives a July 1, 2026 effective date for a post-traumatic stress disorder (PTSD) treatment pilot in workers compensation. The Legislature’s bill status page shows Governor Bob Ferguson signed the bill on March 25, 2026, making this a live reserve issue before the first pilot reports arrive.
The access-to-care story is straightforward: eligible workers who file PTSD occupational disease claims may start treatment before the claim is adjudicated. The reserve story is narrower. Participating self-insured employers can now create paid medical on claims that are not yet allowed, and sometimes on claims that are ultimately rejected.
Who it affects
The direct audience is Washington self-insured cities, counties, hospitals, public safety employers, transit systems, universities, and large private employers with covered trauma-exposed occupations. Captives and public-entity pools that reimburse or front Washington workers compensation risk should watch the same coding issue.
This also matters to multistate employers that already split mental-injury claims by jurisdiction. The Washington change sits beside recent PTSD and mental-injury developments in New York and Wisconsin, but it is different in one important way: Washington is not just changing compensability. It is changing when treatment cost can hit the triangle.
The reserve mechanism
The levers are early medical severity, case reserve adequacy, and development pattern. Under SHB 2405, treatment before adjudication is limited to a diagnostic interview or mental health evaluation and up to 11 PTSD treatment sessions within 90 days of filing. If allowance has not been adjudicated within 90 days, the supervisor of industrial insurance may authorize up to 12 additional sessions. After claim closure, the Department of Labor and Industries and participating self-insurers must authorize up to six more PTSD treatment sessions within one year when needed to maintain the worker’s functioning.
For state-fund claims that are ultimately rejected, the pre-adjudication treatment cost is spread across the risk classes covered by the PTSD presumption. For rejected self-insured claims, the participating self-insurer pays. That is the reserve inflection. A denied claim can still carry pilot medical payments, so denied-claim paid severity should not be blended blindly with allowed-claim severity.
The likely first signal is not a sudden jump in closed indemnity. It is faster paid medical in the first 90 days, followed by a smaller post-closure treatment tail. A recent actuary.info analysis of first-responder mental-injury presumptions makes the broader pricing point: mental-injury law changes often move compensability and severity before traditional loss triangles have enough experience to confirm the shift. For Washington self-insurers in the pilot, that same timing problem shows up in the workers compensation IBNR review as an early paid development question.
What this means for your next review
Put a separate PTSD pilot exhibit on the next reserve agenda. The report should show filed PTSD claims, worker opt-in status, pre-adjudication sessions, allowed or rejected status, paid medical on rejected claims, and any post-closure treatment within one year. Use the reserve diagnostic guide framework to keep this from being misread as ordinary medical inflation or generic case reserve strengthening.
The call is practical: participating employers should create claim-system codes before July 1. If pilot claims are mixed into the standard mental-injury triangle, early payments will make recent accident quarters look heavier, while denied claims with pilot medical payments will make accepted-claim severity look cleaner than it really is. Watch L&I rulemaking, provider agreements, and the first self-insured employer reports requested under the pilot, especially denial rates and average sessions per filed PTSD claim.
Sources
- Washington State Legislature, Final Bill Report, SHB 2405, Chapter 220, Laws of 2026, https://lawfilesext.leg.wa.gov/biennium/2025-26/Pdf/Bill%20Reports/House/2405-S%20HBR%20FBR%2026.pdf
- Washington State Legislature, HB 2405 bill summary and status, https://app.leg.wa.gov/billsummary?BillNumber=2405&Year=2025&Initiative=false
- Washington State Legislature, 2026 Summary of Legislation, SHB 2405 entry, https://leg.wa.gov/media/irtd0mtn/summary-of-legislation-2026.pdf
- Washington bill text, SHB 2405, https://wa-law.org/bill/2025-26/hb/2405/S/
- actuary.info, Pricing a Presumption: First-Responder Mental-Injury Laws Hit WC Class Rates, https://actuary.info/insights/first-responder-presumption-expansion-wc-loss-cost-loading-2026