On April 9th, Healthesystems participated in a Colorado Division of Workers’ Compensation (DOWC) stakeholder listening session where the Division gathered feedback on potential updates to Rule 18 (Medical Fee Schedule).

Healthesystems shared observations related to physician dispensing, noting that while utilization remains relatively low, it represents a disproportionate share of pharmacy costs and encouraged the Division to examine the issue more broadly, potentially through stakeholder discussions or workgroups. The DOWC acknowledged the concern and requested follow up outside the session due to time constraints.

The DOWC also identified two areas under review: missed appointment fees and passive therapy utilization. The Division cited high no-show rates and billing disparities between interpreters and medical providers when injured workers miss an appointment, and noted it is considering whether providers, including physical therapy clinics, should be able to bill for no shows.

Regarding passive therapy, utilization was discussed, with concerns about prolonged use without active treatment. The DOWC invited feedback on improving documentation of functional progress and guideline adherence.

Additionally, interpreter providers raised concerns about increased bill denials related to the mandatory electronic billing that went into effect January 1, 2026. The DOWC clarified that interpreters remain exempt from electronic billing unless contractually required.

Proposed Rule 18 changes are expected in early summer, though the DOWC noted broader policy issues may be addressed in future rulemaking cycles.