Colorado adopts revised workers’ comp medical fee schedule rule

| Nov 12, 2018

The Colorado Division of Workers’ Compensation recently released its updated Medical Fee Schedule rule (Rule 18) and Medical Treatment Exhibits for 2019.  The updated fee schedule will be in effect for all dates of service on or after January 1, 2019.  Of note are several important changes made in the new fee schedule rule for 2019, including but not limited to:

  • Revised and updated RBRVS conversion factors
  • CO specific Z-Code billing codes for topical and patches
  • Revised restriction on prescribing and dispensing of Schedule II and Schedule III opioids when dispensed from a doctor’s office to a maximum of 7 days (previously 30 day-supply permitted)

The amended rule applies to all services rendered on or after January 1, 2019.  All other bills shall be reimbursed in accordance with the fee schedule in effect at time service was rendered.  The 2019 fee schedule has been updated to reflect the most current CPT code terminology, HCPCS codes, Colorado Z-Codes (state-specific billing codes) and Medicare’s most current National Physician Fee Schedule Relative Value file (RBRVS) with updated conversion factors.  As for the revised physician prescribing/dispensing restriction on opioids, the new rule language states:

“Opioids classified as Schedule II or Schedule III controlled substances that are prescribed for treatment lasting longer than 7 days shall be provided through a pharmacy”.

OWCA will move forward to integrate any required process or system changes to drive full compliance with the new rules effective January 1, 2019, including new restrictions on physician dispensing of Schedule II and III opioids.  We strongly urge claims administrators with injured workers receiving care in Colorado to examine the current status of physicians dispensing opioids and communicate new requirements to these treating doctors. 

More information on the fee schedule and Rule 18 can be found here:

Should you have any questions on this or any other public policy development topics, please contact the OWCA Government Affairs team at

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