CA: New Med-Legal Fee Schedule Pending

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CA: New Med-Legal Fee Schedule Pending

A reimagined Medical-Legal Fee Schedule is on the way.

Following the required public hearing and comment period, California’s Division of Workers’ Compensation (DWC) finalized wide-ranging changes to the existing Medical-Legal Fee Schedule in February of this year. However, the state’s Office of Administrative Law (OAL) must approve these changes before the DWC can officially adopt them.

The DWC requested OAL approve the changes for an April 1, 2021 effective date. Upon OAL approval, DaisyBill will host a webinar detailing the revamped fee schedule.

A New Medical-Legal Fee Schedule

Pending OAL approval, the new Medical-Legal Fee Schedule will be very different from its current iteration. The DWC proposed extensive changes to California Code of Regulations (CCR) Sections 9793 through 9795, the regulations which govern reimbursement for Medical-Legal services.

The full text of the pending new fee schedule is available for public viewing on the DWC website. Among the most significant changes:

  • Replacing time-based billing for ML101, ML104, and ML106 with flat fees
  • Substantial increases in reimbursement for evaluations
  • A standardized missed appointment reimbursement ($503.75)
  • Page-based reimbursement ($3.00/page) for medical record review
  • Elimination of complexity factors
  • Increases in reimbursement for medical-legal testimony
  • Increases in reimbursement for reports involving psychiatric issues

According to the DWC:

The implementation of a predominantly fixed fee for all procedure billing codes is anticipated to reduce frictional costs. Moving to a flat-fee-based schedule and removing complexity factors is contemplated to reduce the incidence of disputes over billing.

The DWC made “non-substantial” amendments to the changes before submission to the OAL. The amendments clarify provider requirements regarding record review, remove billing code ML206, and allow QME certified in Internal Medicine to apply certain modifiers to toxicology and oncology evaluations.

DaisyBill will explore the new Medical-Legal Fee Schedule in detail with a dedicated webinar, following OAL approval. Subscribe at the bottom of this page for the latest updates, and for the chance to secure your seat at the webinar.

Need more help with workers’ compensation billing? We’re here for you. Contact DaisyBill to learn how we can make workers’ comp work better for your office.


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