The Texas Division of Workers’ Compensation (DWC) finalized its Calendar Year 2026 Medical Quality Review Annual Audit Plan, selecting topical analgesics as the focus of a plan-based audit. The decision followed stakeholder feedback received in December 2025, including comments from Healthesystems supporting an audit of topical analgesic prescribing.

The DWC will work with system participants to develop the topical analgesic audit, including defining the timeframe, sample size, and case selection. As topical analgesic use continues to increase, audit findings may lead to future DWC reimbursement rule changes, particularly where system wide trends and compliance gaps signal a need for enhanced prescribing oversight and utilization management.

The DWC also indicated it may pursue a separate plan-based audit of utilization review agent peer review reports to assess compliance with Official Disability Guidelines, accepted standards of care, and appropriate reviewer selection, if time and resources permit.