The Texas Department of Insurance, Division of Workers’ Compensation (DWC) is seeking stakeholder input on a proposed Topical Analgesic Plan-Based Audit, which would evaluate prescribing practices for topical analgesic medications in the Texas workers' comp system.

The audit is designed to assess whether topical analgesic prescriptions are medically necessary, reasonable, and supported by appropriate documentation. The DWC will review compliance with the Official Disability Guidelines (ODG), as adopted in 28 Texas Administrative Code § 137.100, by comparing treatment records against the applicable evidence-based guidelines.

The proposed audit would include health care practitioners who prescribed topical analgesics to injured employees between December 1, 2024, and November 30, 2025. The DWC plans to select up to 24 practitioners based on prescription activity during the preceding six months, focusing on providers who issued 32 to 241 topical analgesic prescriptions during that period. For each selected practitioner, up to five patient cases will be randomly selected for review.

Interested stakeholders can email their suggestions for the proposed audit by 5:00 PM CST on August 6, 2026.