As part of a lengthier stakeholder review process that started earlier this year, the Florida Division of Workers’ Compensation (DWC) has formally proposed updates to the Florida Workers’ Compensation Health Care Provider Reimbursement Manual. Prompted by earlier changes in the law related to medical provider reimbursement, the proposed manual updates will ensure the changes in the law are in place for 2025.
Convenience kits
While many of the proposed changes to the manual are more impactful to other medical services, the DWC did include one substantive addition for pharmaceutical reimbursement and authorization.
In the existing manual, the DWC identifies dispensing compounded drugs as a “specialty service” under section 440.13(3)(i) of the Florida Statutes. This means the compounded drug is not reimbursable unless it has been expressly authorized by the carrier (unless the carrier has failed to respond within 10 days to a written request for authorization, or unless emergency care is required).
In the proposed changes, the DWC has added “convenience kits” as a “specialty service,” which would require the same type of authorization by the carrier if that language is adopted.
Though not defined in the manual, “convenience kits” is a term that refers to two or more different products packaged together for the intended convenience of the user. Medication convenience kits commonly seen in workers’ compensation claims are typically used for pain and inflammation. However, these kits often become unnecessary cost drivers given the individual components are available separately at significantly lower prices.
Moving forward
The DWC is receiving comments on the proposed changes and has scheduled a “virtual” public hearing for November 15, 2024, at 10 A.M. eastern time. The MyMatrixx Regulatory Affairs team plans to attend the hearing and provide written comments in support of the new authorization requirement for convenience kits to help curb unnecessary costs in the system. Our comments may include potential questions for clarification on other less substantive proposed language changes or deletions. We encourage interested clients to also attend and provide comments.
The anticipated effective date for any related adopted manual changes is January 1, 2025. The Florida DWC previously stated it intends to address other potential substantive changes next year in further collaboration with stakeholders.
Questions on this topic for our Regulatory Affairs team can be sent to MMXRegulatoryAffairs@MyMatrixx.com. For more information on policy developments like this in workers’ compensation impacting pharmacy in states across the country, please visit and bookmark Statehouse Watch at MyMatrixx.com.