California healthcare providers are not to blame for the state’s grotesquely expensive and inefficient workers’ comp system. Yet, some commentators can’t help but push that narrative.

The latest scapegoating focuses on “unlisted” billing codes that providers use to bill for complex treatments like Functional Restoration Programs (FRPs).

An FRP is a multidisciplinary program to address chronic pain that hasn’t yielded to more conservative treatments. By nature, FRPs require intricate coordination among specialists to develop individualized approaches for workers with different injuries, occupations, pain levels, tolerances, cognitive functioning, emotional regulation, and other variables.

The pundits accusing providers of rampant overbilling ignore the following facts:

• California law requires providers to submit a Request for Authorization (RFA) to obtain payer approval prior to furnishing an FRP program.
• California’s Medical Treatment Utilization Guidelines recommend FRPs where appropriate.
• On multiple occasions, Independent Medical Review (IMR) has overturned payers’ FRP denials. In fact, IMR overturns FRP denials at more than double the overturn rate for all treatments generally.

FRPs are not a loophole, scam, or opportunity for “creative” billing practices. Instead, these programs are widely recognized as a legitimate, if more complex, approach to restoring injured workers to health.