On August 26, 2025, Healthesystems attended the Tennessee Medical Payment Committee meeting to receive updates on the proposed workers’ comp medical fee schedule and other regulatory developments.
Dr. Snyder, Medical Director of the Bureau of Workers’ Compensation (BWC), indicated that the proposed fee schedule, which includes adding Medicare’s negotiated price to the “lesser of” for pharmaceuticals and increasing Medicare rate percentages, is currently under review by the Attorney General’s Office. No timeline for approval was provided. Once finalized, the rules will be published on the Secretary of State’s website and will take effect within 90 days.
During the public comment period, Healthesystems submitted feedback urging the removal of the Medicare negotiated price due to concerns about the absence of markup and its potential impact on patient access. The Committee did not specify which stakeholder recommendations would be adopted.
Concerns were also raised regarding disputes involving Tennessee-specific “Z” codes, which provide additional reimbursement to certified physicians treating workers’ comp patients. Improper application of these codes by payers led the Committee to issue corrective letters to four companies.
The meeting concluded with a review of WCRI and NCCI data. Tennessee ranked 27th out of 36 states in professional service payment rates, placing it among the five lowest. Although Tennessee’s rates are within 5% of most states with fee schedules, they remain below the median and significantly lower than states without fee schedules.
From 2008 to 2024, Tennessee’s professional services payment growth was only 8%, compared to the national average of 30%. This supports proposed increases of 30% for physical therapy and 20–40% for other services. NCCI’s analysis of the April 2025 fee schedule changes showed minimal impact on overall medical costs, including:
- Physician services: decreasing less than 0.6%
- Hospital outpatient services: increasing 0.3%
- Ambulatory surgical centers (ASCs): increasing 3%
Attending these meetings keeps stakeholders informed on regulatory developments and the Bureau’s data-driven policy decisions. Of particular concern, the proposed use of Medicare’s negotiated price for pharmaceutical reimbursement without a markup could discourage provider participation and limit access to care. Furthermore, those negotiated rates primarily impact medications not commonly used in workers’ comp. This has the potential to limit practical value and introduce unnecessary administrative complexity without improving cost control or care outcomes.
The next Medical Payment Committee meeting is scheduled for October 14, 2025.
