Colorado’s Division of Workers’ Compensation was busy in 2025, implementing several changes to the existing Rules of Procedure.Important deadlines and Rule changes for 2025 include the following.
Effective January 1, 2025:
Based on a review of updated medical evidence, and consultation with the medical community, Rule 17, Exhibit 4, Medical Treatment Guidelines for Shoulder Injury underwent a complete overhaul. The new Rule focuses on evidence-based care, emphasizing functional gains for the patient. Due to the extensive nature of the revisions, a red-lined version showing changes from the old rule was not made available. You can find the new rule at https://codwc.app.box.com/v/rule-17-exhibit-4.
January 1, 2025, also brought updates to Rule 16, Utilization Standards, and Rule 18, Colorado’s Medical Fee Schedule, including changes to payment policies, status indicators, and payment percentages for medical providers. In another key change, per Rule 18, all prescriptions for gabapentin must now be filled through a pharmacy. See https://codwc.app.box.com/v/Rule16-Utilization-Standards and https://codwc.app.box.com/v/Rule18-Fee-Schedule.
Effective April 1, 2025:
As of April 1, 2025, an updated Rule 11 completely overhauled the Division Independent Medical Examination process. A new unit within the DOWC, the Medical Records Unit, now manages a system to collect, organize, and create the DIME medical records packet. The Rule also makes changes to DIME physician qualifications to include specific experience and certification criteria for providers to join the DIME Panel. The Rule implements a new fee structure with an initial $1,000 deposit and additional time for record review billed in 15-minute increments. The updates to Rule 11, W.C.R.P., are designed to improve the DIME process’s efficiency, fairness, and timeliness, as well as to aid in the recruitment, and retention, of DIME physicians. In connection with the Rule change, seven key DIME-related forms were revised. Out-dated forms will be rejected by the Division. The new Rule 11, W.C.R.P., can be found at https://codwc.app.box.com/v/rule-11-medical-exam.
Effective July 1, 2025:
The Division eliminated Rule 16’s requirement that a physician personally exam an injured worker within the first three medical visits, provided the worker is under the care of a Physician Assistant or Nurse Practitioner. While direct supervision is no longer required, the supervising physician must remain “in charge of the care” provided by the PA or NP and must continue to sign off on all reports regarding the injured worker’s accident-related work restrictions. A physician examination is now only required if: (1) The supervising PA or NP deems it medically necessary; (2) The supervising physician deems it medically necessary; or (3) An involved party, i.e., the injured worker, employer, or insurer requests an exam. See https://codwc.app.box.com/s/8vr5l0hfvclt53z1m6bhcwxne4uqaokb.
Effective August 1, 2025:
Beginning August 15, 2025, the Division will reject any forms submitted for approval, if they are not the most current version. According to the Division, outdated forms including Applications for Indigent Determination, Settlement Agreements, Settlement Orders, and Requests for Disfigurement Awards, will be rejected, no exceptions. While the Division highlighted the forms listed above, the general rule is all submissions must be the latest version available on the DOWC website at https://cdle.colorado.gov/dwc.
Effective November 3, 2025:
While not a Rule change, the Colorado Department of Labor and Employment, and its Division of Workers’ Compensation, announced it is moving its headquarters to 707 17th Street, Denver, Colorado 80202. It will begin serving customers at the new address on November 3, 2025.
Please feel free to contact any of the attorneys at BGAM Law if you have any questions regarding recent Division Rule changes and updates, any issue involving workers’ compensation, or any of our other practice areas.
