The Colorado workers’ comp fee schedule is set by Rule 18 of the Workers’ Compensation Rules of Procedure and caps what medical providers can charge for treating an injured worker. The Division of Workers’ Compensation updates the rates each January 1, and charging above the schedule is unlawful under Colorado statute. Injured workers cannot be billed for the difference between a provider’s usual rate and the fee schedule maximum.1FindLaw. Colorado Revised Statutes Title 8 – 8-42-101
How Reimbursement Is Calculated
Rule 18 uses the Resource-Based Relative Value Scale, the same framework Medicare uses. Every procedure has a set of Relative Value Units covering physician work, practice overhead, and malpractice cost. The Division multiplies those units by a Conversion Factor, and the result is the maximum allowable payment for that code.2Cornell Law Institute. 7 CCR 1101-3-18-4 – Professional Fees and Services
Providers receive the lesser of their actual charge or the schedule amount, so the number functions as a ceiling. Because the Conversion Factor changes annually, the same code can produce a different maximum from one year to the next.
2026 Conversion Factors
Colorado uses different Conversion Factors for different categories of care:2Cornell Law Institute. 7 CCR 1101-3-18-4 – Professional Fees and Services
- Anesthesia: $44.00
- Surgery, Radiology, Pathology, and Medicine: $66.58
- Physical Medicine and Rehabilitation (including medical nutrition therapy and acupuncture): $49.93
- Evaluation and Management: $58.25
To find the maximum payment, multiply the procedure’s total Relative Value Units by the appropriate Conversion Factor above.
Reduced Rate for PAs and Nurse Practitioners
Physician Assistants and Nurse Practitioners are paid at 85% of the fee schedule for most services. The exception is a mid-level provider who meets the Rule 16 credentialing requirements and practices in a rural area, who receives the full 100% rate.2Cornell Law Institute. 7 CCR 1101-3-18-4 – Professional Fees and Services
Hospital and Facility Rates
Facility charges follow a different methodology than professional services, and the calculation depends on the setting. In every case the facility receives the lesser of its actual charge or the fee schedule amount.3Colorado Secretary of State. 7 CCR 1101-3 Rule 18 – Medical Fee Schedule
Inpatient Hospital
Most inpatient admissions use a formula built on Medicare Severity Diagnosis Related Groups. Multiply the MS-DRG relative weight by the hospital’s specific base rate (listed in Rule 18’s Exhibit 2), then apply a 160% multiplier. Trauma center activation fees and organ acquisition costs are added when they apply. Children’s hospitals, VA hospitals, and state psychiatric facilities fall outside this formula and negotiate a reasonable charge directly with the payer.3Colorado Secretary of State. 7 CCR 1101-3 Rule 18 – Medical Fee Schedule
Outpatient and Ambulatory Surgery
Outpatient facility fees are set as a percentage of Medicare’s Outpatient Prospective Payment System rates:3Colorado Secretary of State. 7 CCR 1101-3 Rule 18 – Medical Fee Schedule
- Outpatient hospital: 160% of Medicare OPPS
- Critical Access Hospital: 200% of Medicare OPPS
- Ambulatory Surgery Center: 150% of Medicare OPPS
Daily-Rate Facilities
A few facility types use a flat per-day rate instead:3Colorado Secretary of State. 7 CCR 1101-3 Rule 18 – Medical Fee Schedule
- Skilled Nursing Facility: $663 per day
- Rehabilitation Hospital: $1,479 per day
- Long-Term Acute Care Hospital: $3,417 per day
Prescription and Injectable Drugs
Prescription drugs are priced at Average Wholesale Price plus a $4.00 dispensing fee. That applies to brand-name and generic prescriptions alike, whether written in the first 30 days after injury or later. Repackaged drugs must be billed at the original AWP and NDC from the source manufacturer, not the repackager’s price.4Colorado Secretary of State. 7 CCR 1101-3 Rule 18 – Medical Fee Schedule
Injectables administered by a provider during care are paid at actual cost or Medicare’s Part B Average Sale Price. Over-the-counter medications are reimbursed at AWP with no dispensing fee. If AWP data becomes unavailable, Rule 18 substitutes Wholesale Acquisition Cost plus 20%.4Colorado Secretary of State. 7 CCR 1101-3 Rule 18 – Medical Fee Schedule
Special Reports and Party-Requested IMEs
Special reports, including independent medical evaluations requested by a party outside the Division’s formal IME process, are capped at $325.00 per hour, billed in 15-minute increments. An Administrative Law Judge can authorize higher fees for good cause on a case-by-case basis.4Colorado Secretary of State. 7 CCR 1101-3 Rule 18 – Medical Fee Schedule
Billing Forms and Coding
Rule 16 dictates which form to use. Professional services, durable medical equipment, prosthetics, orthotics, supplies, and ambulance services go on the CMS-1500. Non-hospital-based ambulatory surgery centers may also use the CMS-1500 but must append an SG modifier to the technical component. Hospitals, facilities, hospital-based ambulance and air services, and hospital-based ambulatory surgery centers billing for facility services use the UB-04.5Colorado Department of Labor and Employment. 7 CCR 1101-3 Rule 16 – Utilization Standards
Services must be coded with CPT, HCPCS, and NDC codes, paired with ICD-10 diagnosis codes that establish medical necessity. Modifiers can raise or lower reimbursement depending on the circumstances. A missing modifier or the wrong code produces a denial or a reduced payment, and coding accuracy is the provider’s responsibility.
Electronic Billing in 2026
Beginning in 2026, providers who submit 25 or more workers’ compensation bills per month must bill electronically using HIPAA-compliant transactions whenever the payer has connectivity with the provider’s system or clearinghouse. Self-insured employers are exempt. When a bill is submitted electronically, a duplicate paper bill is not allowed.
Workers’ compensation insurers themselves are not classified as “health plans” under HIPAA, so the transactions are not technically HIPAA-covered. Providers who are HIPAA-covered entities still have to comply with the HIPAA Security Rule when transmitting protected health information electronically, including to a workers’ compensation payer.
Deadlines, Payment, and Interest
A bill must be submitted within 120 days of the date of service, or it can be denied. Rule 16 allows an exception for extenuating circumstances, but the 120-day window is the default.6Colorado Department of Labor and Employment. 7 CCR 1101-3 Rule 16 – Utilization Standards
Once the payer has a complete bill, it has 30 days to pay or issue a written denial explaining the reduction. Miss that window and interest accrues at 8% per year, calculated daily, starting on the 31st day after receipt through the date of actual payment.6Colorado Department of Labor and Employment. 7 CCR 1101-3 Rule 16 – Utilization Standards
A provider who submits a clean bill early leaves the insurer no room for delay. A provider who waits until day 110 has little margin left if the first bill is rejected for a coding error.
No Balance Billing the Injured Worker
The injured worker cannot be billed for the gap between the provider’s usual rate and the fee schedule maximum. Rule 16 requires the payer to notify the billing party of that prohibition.5Colorado Department of Labor and Employment. 7 CCR 1101-3 Rule 16 – Utilization Standards
If a worker paid out of pocket for care that is later admitted or ordered under the Workers’ Compensation Act, the payer has to reimburse the worker within 30 days of receiving the bill. Where the worker paid more than the schedule allows, the payer can seek a refund from the provider for the excess.5Colorado Department of Labor and Employment. 7 CCR 1101-3 Rule 16 – Utilization Standards
By statute, any physician, chiropractor, hospital, or other provider who charges any party more than the schedule allows for a workers’ compensation service is acting unlawfully, and the excess is void and unenforceable as a debt.1FindLaw. Colorado Revised Statutes Title 8 – 8-42-101
Disputing an Underpayment
The first step is informal reconsideration. A provider who believes a bill was underpaid submits a written request to the carrier within 60 days of receiving the payment notice, explaining why. Coding errors and missing documentation are often resolved at this stage without state involvement.
If the carrier denies reconsideration or the adjusted payment is still too low, the provider can file a formal fee dispute with the Colorado Division of Workers’ Compensation. The Division reviews the evidence against Rule 18 and issues a binding determination on the correct reimbursement. The 8% annual interest penalty applies to any amount the Division finds was not paid on time.6Colorado Department of Labor and Employment. 7 CCR 1101-3 Rule 16 – Utilization Standards
Where To Find the Current Schedule
The Division of Workers’ Compensation publishes the current fee schedule, along with downloadable Excel tables of procedure codes and maximum allowances, on its website.7Department of Labor and Employment. Fee Schedule Rule 18 The full text of Rule 18 effective January 1, 2026 is posted on the Colorado Secretary of State’s Code of Colorado Regulations site. Because Conversion Factors and facility base rates change every year, confirm you are looking at the version in effect on the date of service, not the version current when the bill goes out.