The Colorado Division of Workers’ Compensation (DWC) has adopted changes to its regulations governing utilization standards and medical fees. Two notable amendments within the rules include:
- The addition of gabapentin to the list of drugs that must be dispensed by a pharmacy (not a physician or other practitioner)
- An electronic medical billing and processing requirement for many payers and providers
Physician dispensing of gabapentin
The DWC amended an existing regulation provision to add gabapentin to the list of medications that must be dispensed by a pharmacy and not a physician or other practitioner. The existing list already includes scheduled, controlled substances, including opioids and benzodiazepines. The language was also simplified based on stakeholder recommendations given the existing categories listed were somewhat duplicative.
With this amended rule taking effect January 1, 2025, payers may expect to see less physician dispensing of gabapentin in their Colorado claims. MyMatrixx by Evernorth will work to implement this stricter requirement into our processes.
Electronic billing, processing, and payment
The DWC added several requirements related to billing, processing, and payment.
- Effective January 1, 2026, all payers (insurers or designated agents like a PBM) other than self-insured employers will be required to:
- Accept electronic bills (eBills) from providers (physicians, pharmacies)
- Acknowledge the receipt of eBills electronically within two working days of bill submission
- Provide an electronic remittance advice to the provider no later than 30 days after receipt of a complete eBill or within five days of generating a payment to the provider
Effective January 1, 2026, providers, or their billing representatives, who submit 25 or more workers’ comp medical bills per month, must submit bills via a HIPAA-compliant electronic transaction to payers with established connectivity to the provider’s system or clearinghouse. The national standard formats to be used are outlined in the regulations. Providers must follow the payer’s requirements for submission of attachments, whether by electronic submission, mail, fax, email or web upload.
Required data elements in the DWC adopted formats must be presented in a mutually agreed upon format. Payers and providers will be permitted to exchange electronic data in a non-prescribed format by mutual agreement.
- Payers must offer a provider at least one method of payment that does not require a fee and does not limit the only acceptable payment form or method to a credit card payment. If a payer uses electronic funds transfer (EFT), including virtual credit card payments, they will be required to notify the provider if any fee is associated with a particular payment method, advise the provider of the available payment methods, and provide clear instructions on how to select an alternative.
Moving forward
With the eBilling and processing mandates not scheduled to take effect until 2026, the DWC is planning to establish an electronic billing task force to review the topic. The MyMatrixx Regulatory Affairs team has been invited to participate in that group, and we intend to take part in those discussions to assist the DWC with implementation of the eBilling requirements.
MyMatrixx accepts transactions electronically from network pharmacies in the national standard pharmacy formats adopted by the DWC, and we believe electronic billing and greater standardization of it fosters greater efficiencies in the healthcare and workers’ comp. systems.
For context, while eBilling is common (especially between pharmacies and PBMs), mandatory eBilling and processing requirements for both provider and payer are rare in workers’ compensation, with only a few states requiring both sides to transact electronically. The International Association of Industrial Accident Boards and Commissions (IAIABC), which has adopted an electronic billing model rule for states to utilize, maintains a map of states with current eBilling mandates, which can be referenced here. In 2026, look for Colorado to be added to that map.
Full details on these rule changes can be viewed here:
For more policy developments like this in workers’ compensation impacting pharmacy in states across the country, please visit and bookmark Statehouse Watch at MyMatrixx.com.