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Policy Matters Brief – July 2026

July 22, 2026 · Public Policy & Regulatory Affairs Team

Alaska MSRC advances review of medical fee schedule updates

The Alaska Workers’ Compensation Division’s Medical Services Review Committee (MSRC) is reviewing potential updates to the state’s workers’ compensation medical fee schedule as part of its ongoing summer review process. On June 26, the MSRC discussed several pharmacy-related issues, including physician dispensing, compounds/topicals, and repackaging. The committee is expected to continue evaluating these issues at its upcoming meetings on July 17 and August 7. Further information can be found on the Division’s website by clicking here.

Arizona continues review of topical medication reimbursement limits

The Industrial Commission of Arizona (ICA) continues to refine proposed changes to its workers’ compensation pharmacy fee schedule that addresses prescription topical medications. In late June, the agency’s Medical Resource Office (MRO) distributed a fourth informal draft to stakeholders that would:

  • Require pharmacies to submit documentation supporting the acquisition cost of any topical medication exceeding $300 for a 30-day supply. Reimbursement for the initial fill would be limited to 120% of the documented acquisition cost, plus a $7 dispensing fee.
  • Reimburse subsequent fills of the same medication would be reimbursed at the lower of:
    • The amount under the standard AWP-based fee schedule amount; or
    • A $300 cap (prorated to a 30-day supply), plus a $7 dispensing fee.
  • Permit reimbursement above the cap for subsequent fills only if the pharmacy submits provider-certified clinical documentation demonstrating that:
    • The prescribed topical medication is medically necessary for the injured worker’s treatment; and
    • No lower-cost therapeutic alternative is appropriate for the patient.

The proposal remains under stakeholder review, and additional revisions may be made before the ICA initiates a formal rulemaking process.

California advances reimbursement transparency bill as DWC updates fee schedules

Assembly Bill 1048
The California Legislature is considering AB 1048, a bill that would affect reimbursement disputes by requiring payers to furnish providers with contract information that supports reimbursement reductions. The bill proposes that if a payer relies on a contracted rate to reduce payment and the provider requests supporting documentation, the payer would be required to furnish a copy of the applicable contract.

The bill would also require explanations of benefits (EOBs) to include the state-assigned Medical Provider Network (MPN) identification number, as well as an email address providers can use to request a copy of the underlying contract.

The bill (https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB1048) passed the Assembly and is currently awaiting a hearing before the Senate Appropriations Committee.

Medical Fee Schedule Updated
The California Division of Workers’ Compensation (DWC) has updated several medical treatment and Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) fee schedules to reflect recent changes in Medicare reimbursement rates. Because California’s workers’ compensation medical and DMEPOS fee schedules are tied directly to Medicare payment methodologies, updates to Medicare rates generally require corresponding revisions by the DWC.

The DWC has updated the following fee schedules effective July 1, 2026:

  • DMEPOS
  • Physician services and non-physician practitioner services
  • Hospital and outpatient services
  • Ambulatory surgical centers
  • Laboratory and pathology services

More information on the fee schedules can be found by clicking here.

Colorado schedules August hearing on proposed Rule 16 and Rule 18 revisions

The Colorado Division of Workers’ Compensation has scheduled a rule hearing for proposed changes to Rule 16 and Rule 18 for August 27, at 10:00 a.m. MDT. The public may testify during the hearing, and written comments may be submitted by email to amy.kingston@state.co.us prior to the hearing.

Proposed Rule 16 and Rule 18 materials (including the Rule 16 redline and Rule 18 change list) are available through the Division’s hearing notice by clicking here.

Florida extends Workers’ Compensation Reimbursement Dispute deadlines

Florida has enacted Senate Bill 1452, which extends key deadlines within the state’s workers’ compensation medical reimbursement dispute process.

Under the new law, health care providers now have 60 days (increased from 45 days) to file a reimbursement dispute petition with the Division of Workers’ Compensation (DWC) after a carrier adjusts or denies payment for a medical bill.

The legislation also extends the deadline for carriers and claims administrators to respond to a reimbursement dispute petition. Payers now have 45 days (up from 30 days) to submit a response and provide documentation the payment adjustment or denial supporting the payment adjustment or denial.

The revised timelines provide additional time for both providers and payers to prepare and submit documentation during the reimbursement dispute process. Providers have a longer window to challenge payment determinations, while carriers and claims administrators gain additional time to compile and present supporting evidence in response to filed disputes.

The legislation does not modify Florida’s existing requirement that workers’ compensation medical bills must be paid, adjusted, or denied within 45 days of receipt.

The full text of SB 1452 can be reviewed by clicking here

Kentucky updates 2026 physician fee schedule

The Kentucky Department of Workers’ Claims has issued its updated 2026 Workers’ Compensation Schedule of Fees for Physicians, effective July 1, 2026, updating maximum allowable reimbursement rates for physician services and certain other medical services.

Importantly, this update does not change pharmacy reimbursement. Payment for prescription drugs, physician-dispensed medications, repackaged drugs, compounds, dispensing fees, and related pharmacy-payment rules continues to be exclusively governed by the separate Kentucky Workers’ Compensation Pharmacy Fee Schedule, 803 KAR 25:092. In the event of any conflict, the Pharmacy Fee Schedule is the final word.

The new schedule is available on the Department’s Medical Services/Fee Schedules webpage Medical Services - Kentucky Education and Labor Cabinet.

Michigan proposal would limit practitioner-dispensed drug reimbursement

The Michigan Workers’ Disability Compensation Agency has proposed updates to its Workers’ Compensation Health Care Services rules, including a new limitation that would limit reimbursement for medications dispensed by practitioners in an office or clinical setting to the first 42 days of medical treatment provided under Section 315 of the Worker’s Disability Compensation Act. 

The proposed rule changes also update 2026 coding references and include related billing and reimbursement revisions. 

A public hearing is scheduled for July 24, 2026, at 1:30 p.m., and written comments are due the same day. Comments may be submitted to LEO-WDCA, Attention: Carrie Ross, P.O. Box 30016, Lansing, MI 48909, or by email to WCINFO@michigan.gov.

Mississippi seeks to restore topical drug reimbursement cap after fee schedule omission

The Mississippi Workers’ Compensation Commission has proposed a corrective amendment to its medical fee schedule after language limiting reimbursement for manufactured topical medications was inadvertently omitted from fee schedule updates that took effect on June 1, 2026.

The proposed amendment would reinstate the previous reimbursement limits for manufactured (non-compounded) topical medications without changing the substance of the prior rule. Although the amendment would not alter the substance of the previous provision, it would reinstate the reimbursement cap as it existed before the June 2026 revisions. Maximum allowable reimbursement for manufactured topical medications, excluding patches, would remain the billed charge up to $30 for a 30-day supply, prorated when a lesser quantity is dispensed.

Formal notice of the proposed correction was published on June 29, with an anticipated effective date of September 1, 2026. The amendment is intended to close a potential reimbursement loophole and preserve existing controls on topical medication costs within the workers’ compensation system. The formal notice can be read by clicking here.

Montana readopts ODG Drug Formulary, updates medical regulations

The Montana Department of Labor & Industry has adopted updates to several workers’ compensation medical regulations, including the annual re-adoption of the ODG Drug Formulary as required by state law. These amendments preserve Montana’s current approach to drug formulary administration while ensuring annual compliance with statutory requirements and maintaining reimbursement standards. The Notice of Adoption can be read by clicking here.

Vermont proposes major overhaul of workers’ compensation medical fee schedule

The Vermont Department of Labor has proposed a comprehensive update to Rule 40, the Workers' Compensation Medical Fee Schedule.

The proposal would modernize the fee schedule by expanding its CPT/HCPCS-based reimbursement structure, implementing annual fee updates tied to CMS market basket indices (capped at 3% annually), and updating reimbursement methodologies for hospitals and ambulatory surgery centers. Additional charges include revised anesthesia and dental reimbursement provisions, expanded coding and billing requirements, and new reimbursement provisions for independent medical examinations (IMEs), impairment ratings, and depositions.

A public hearing will be held on August 3, 1:00 to 3:00 p.m. in the lobby conference room at 5 Green Mountain Drive, Montpelier. Public comments will be accepted through August 14th. To provide comments, email VTfeedback@fairhealth.org.

You can join the public hearing on August 3 on Microsoft Teams by using this link: https://teams.microsoft.com/meet/215735828885071?