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Notes · reference

Florida workers' comp for treating practices: the provider handbook (2026)

Clearia · September 2026 · workers' comp, Florida · reference

Last verified against the primary documents: September 20, 2026. Statutes, rules, and payer manuals change; the current text controls.

On this page

  1. What the carrier owes: the maximum reimbursement allowances
  2. Authorization: the three-day and ten-day rules
  3. Billing and reporting duties
  4. The carrier's clocks on the bill
  5. The EOBR and every code it can carry
  6. The dispute: a petition to the Department
  7. What a pattern of underpayment costs the carrier
  8. The market you are billing into
  9. The operating checklist

Florida workers' comp pays treating practices under one state regime, not under each carrier's own rules. The rates are in the statute. The deadlines are in the statute and in two administrative rules. The dispute goes to a state agency, not to the carrier's appeals unit. That makes it the most predictable payer a Florida practice bills, and the least forgiving, because the clocks are short and the rules on service and paperwork are strict.

This handbook is the working reference we use. Every rule below is quoted from the primary document and cited to the paragraph. Where the corpus we hold does not contain a document, we say so rather than fill the gap from memory.

1. What the carrier owes: the maximum reimbursement allowances

Since the 2025 legislative change, physician services and surgical procedures are paid at a multiple of Medicare. The percentages sit in the statute itself, in section 440.13(12).

(f) Maximum reimbursement for a physician licensed under chapter 458 or chapter 459 shall be 175 percent of the reimbursement allowed by Medicare, using appropriate codes and modifiers or the medical reimbursement level adopted by the three-member panel as of January 1, 2003, whichever is greater.§440.13(12)(f), Florida Statutes (2025)
(g) Maximum reimbursement for surgical procedures shall be 210 percent of the reimbursement allowed by Medicare or the medical reimbursement level adopted by the three-member panel as of January 1, 2003, whichever is greater.§440.13(12)(g), Florida Statutes (2025)

The effective date and the prior rates are not in the statute text. They are in the Office of Insurance Regulation's 2025 annual report, which describes the bill that made the change.

SB 362, Medical Treatment under the Worker's Compensation Law, became effective January 1, 2025. [...] the reimbursement limitation relative to Medicare for physician services was increased from 110 percent to 175 percent, and the reimbursement limitation relative to Medicare for surgical procedures was increased from 140 percent to 210 percent. NCCI estimated this bill would result in an impact of +5.6% on overall workers compensation system costs.Florida Office of Insurance Regulation, 2025 Workers' Compensation Annual Report, p. 19

Three things follow for a practice.

Deviation below the schedule is allowed only where the provider "specifically agrees in writing to follow identified procedures aimed at providing quality medical care to injured workers at reasonable costs" (§440.13(13)(b)). No writing, no deviation. The schedule also applies to the practice's own conduct: fees "must not exceed the amounts provided by the uniform schedule" (§440.13(12)(i)), and that includes independent medical examinations.

Florida's own bundling and multiple-procedure rules

The 2024 edition of the Health Care Provider Reimbursement Manual, effective January 1, 2025, sets rules that differ from Medicare's in several places. A bill-review vendor that applies Medicare or NCCI logic where the manual says otherwise is underpaying.

RuleFlorida workers' comp (manual, 2024 ed.)Where it differs from Medicare
Consultations"A physician must be reimbursed for consultations, confirmatory consultations, and follow-up consultation services." (p. 16)Medicare stopped paying consultation codes in 2010.
Assistant surgeon (modifier 80)"twenty-five percent (25%) of the physician MRA." (p. 29)Medicare pays 16%.
Non-physician surgical assistant (AS)"seventy-five percent (75%) of twenty-five percent (25%) of the physician MRA." (p. 30)Medicare: 85% of 16%.
Co-surgeons (modifier 62)"Sixty-two and one-half percent (62.5%) of the listed MRA" to each. (p. 30)Same as Medicare.
Multiple surgery (modifier 51)Primary at the MRA; "Fifty percent (50%) of the MRA" for additional procedures. Add-on codes exempt. (p. 30)No further step-down below 50% for third and later procedures.
Bilateral (modifier 50)"One hundred and fifty percent (150%) of the MRA, unless otherwise stated." (p. 31)Same as Medicare.
Bilateral code done unilaterally (52)"Fifty percent (50%) of the MRA." (p. 31)Stated rule, not carrier discretion.
E/M visits"one (1) evaluation and management visit per day at the level of care documented." (p. 16)State cap.
Telemedicine"reimbursed using the same MRA as a face-to-face visit." (p. 16)Parity is written.
Physical medicineOne visit per day unless authorized; "no more than four (4) units of service must be reimbursed per visit"; re-evaluation no more than once every four weeks. (pp. 24 to 25)Four-unit cap has no NCCI equivalent.
Global packageFollow-up days per the fee schedule; ZZZ add-ons paid the same as the parent; YYY global "set by the carrier." (p. 29)Similar structure, state-specific table.
Anesthesia"MRA = Total Anesthesia Units x $29.49 (CF)" (p. 12)State conversion factor.

On coding edits, the manual is explicit about hierarchy. Carriers "must use the codes and descriptions, modifiers, guidelines, definitions, and instructions of the incorporated reference material" and, "where not inconsistent with instructions in this Manual, carriers may utilize the National Correct Coding Initiative (NCCI) edits" (p. 6). NCCI is optional and subordinate. A bundling denial that contradicts the manual is disputable on that sentence alone.

What the manual does not contain matters too. It has no PPO, network, discount, or "silent PPO" provision of any kind. The only alternative to the MRA it recognises is "an agreed upon contract price." The rule that a network's name must appear when a carrier pays "pursuant to written contractual arrangement" is in the EOBR code list, not in the manual (see code 93 below).

2. Authorization: the three-day and ten-day rules

Authorization is a condition of payment. The statute puts the burden on the provider to get it and on the carrier to answer quickly.

(a) As a condition to eligibility for payment under this chapter, a health care provider who renders services must receive authorization from the carrier before providing treatment. This paragraph does not apply to emergency care.§440.13(3)(a)
(d) A carrier must respond, by telephone or in writing, to a request for authorization from an authorized health care provider by the close of the third business day after receipt of the request. A carrier who fails to respond to a written request for authorization for referral for medical treatment by the close of the third business day after receipt of the request consents to the medical necessity for such treatment. All such requests must be made to the carrier. Notice to the carrier does not include notice to the employer.§440.13(3)(d)

Read the second sentence carefully. The deemed consent attaches to a written request for authorization for referral for medical treatment, and what the carrier concedes is medical necessity. It does not turn silence into a blanket authorization of anything the practice wants to bill, and it does nothing for a phone request nobody can prove. Send authorization requests in writing, to the carrier (not the employer), and keep the transmission record.

A second, longer clock applies to higher-value services.

(i) Notwithstanding paragraph (d), a claim for specialist consultations, surgical operations, physiotherapeutic or occupational therapy procedures, X-ray examinations, or special diagnostic laboratory tests that cost more than $1,000 and other specialty services that the department identifies by rule is not valid and reimbursable unless the services have 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. [...] Authorization of a treatment plan does not constitute express authorization for purposes of this section, except to the extent the carrier provides otherwise in its authorization procedures.§440.13(3)(i)

Two traps in that paragraph. First, "express" authorization is required for that list, and approval of a treatment plan on the DWC-25 is not express authorization unless the carrier's own procedures say so. Second, the statute says "10 days" without saying business days. The rule chapter defines days as calendar days unless otherwise noted, but that definition governs the rules, not the statute. Treat it as ten calendar days and you will never be late.

Emergency care has its own notice duties: notify the carrier "by the close of the third business day" after rendering it, and "by telephone within 24 hours after initial treatment" if the worker is admitted (§440.13(3)(b)). Referrals to another provider, facility, or therapy centre need prior authorization except in an emergency (§440.13(3)(c)).

The rule adds the form the carrier's answer must take: "Any response to a request for authorization must be communicated electronically or by telephone to the health care provider and must be documented in the claims administration system" (Rule 69L-7.740(2)(c)). At the time of authorization, the carrier must also tell the provider in writing what documentation beyond the rule and manual it will require for payment (69L-7.740(2)(a)), whether it intends to apportion for a pre-existing condition (69L-7.740(2)(b)), and "the specific address for submitting a reimbursement request" (69L-7.740(3)).

The provider's side of the record is a payment condition too. The manual (p. 5) requires the practice to record "The date(s) on which the authorization was requested and received (whether verbally or in writing); The name of the carrier or its designated entity; and The name of the person authorizing." Failure to produce that record "may result in the health care provider being ineligible for payment." A practice that logs those three fields on every authorization has already won most code-30 disputes.

3. Billing and reporting duties

4. The carrier's clocks on the bill

45 days to adjudicate. The duty comes from section 440.20(2)(b), which the corpus we hold does not contain. The rule that implements it does, and it is unambiguous:

(12) A claim administrator or any entity acting on behalf of the insurer shall pay, adjust, disallow or deny billed charges within 45 days from the 'Date Insurer Received Bill,' pursuant to Section 440.20(2)(b), F.S.Rule 69L-7.740(12), F.A.C.

The clock starts when the bill "is in the possession of the claim administrator or any entity acting on behalf of the insurer" (Rule 69L-7.710(1)(o)), and the carrier must date-stamp it on that date (69L-7.740(9)). Your own proof of transmission is what makes the 45 days enforceable.

21 days to return a deficient bill. A carrier that finds a bill deficient must "either: 1. Secure and/or correct the information on the medical bill and proceed to make a reimbursement decision [...] within 45 days [...]; or 2. Return the medical bill to the provider within twenty-one (21) days of the 'Date Insurer Received Bill' with a written statement identifying the deficiency criteria" (69L-7.740(11)(c)). The statement must carry, capitalized and in bold, "A HEALTH CARE PROVIDER MAY NOT BILL THE INJURED EMPLOYEE FOR SERVICES RENDERED FOR A COMPENSABLE WORK-RELATED INJURY."

A return without an EOBR is allowed only on seven listed deficiencies: wrong billing form; wrong insurer; wrong claim administrator; injured-employee identification illegible or incorrect; billing information illegible; or billing information "omitted or incomplete" (69L-7.740(11)(g)). For the last four, the carrier's statement "shall identify the information that is illegible, incorrect, or omitted" (11)(e). Anything else must come back as an EOBR with a code. A "returned" bill that fits none of the seven is an adjudication the carrier failed to make on time.

Corrected codes must be shown. A carrier may correct a procedure code, modifier, or NDC to effect payment, but it "shall report both the provider billed code(s) and insurer adjusted code(s)" and "shall utilize the EOBR code '80'" to tell the provider (69L-7.740(8)). A silent recode is a rule violation.

The carrier owns every vendor's error.

(1) An insurer is responsible for meeting its obligations under this rule regardless of any business arrangements with any claim administrator or any entity acting on behalf of an insurer under which medical bills are paid, adjusted, disallowed, denied, or otherwise processed or submitted to the Division.Rule 69L-7.740(1), F.A.C.

The manual (p. 5) repeats it: a carrier "is accountable regardless of any business arrangements with any service company, TPA, submitter, or any entity acting on behalf of the carrier." Address the petition to the carrier's designee and argue against the carrier. The bill-review company is not a party.

5. The EOBR: the only notice you will get, and every code it can carry

Workers' comp carriers in Florida do not send a remittance in the commercial sense. They send an Explanation of Bill Review, and the rule is strict about what it must contain and what it must say.

A claim administrator or any entity acting on behalf of the insurer shall notify the health care provider of notice of payment or notice of adjustment, disallowance or denial only through an EOBR. An EOBR shall specifically state that the EOBR constitutes notice of disallowance or adjustment of payment within the meaning of Section 440.13(7), F.S. An EOBR shall specifically identify the name and mailing address of the entity the carrier designates to receive service on behalf of the 'carrier and all affected parties' for the purpose of receiving the petitioner's service of a copy of a petition for reimbursement dispute resolution by certified mailRule 69L-7.740(14), F.A.C.

Each line carries up to three codes "in descending order of importance" (69L-7.740(13)(a)), and only the codes in the rule may be used, with the insurer's name, Division code number, and mailing address. Four defined words explain the families: Pay means the formula was applied to the bill as submitted; Adjust means "payment is made with modification"; Disallow means no payment on a compensable injury "for reasons of medical necessity, insufficient documentation, lack of authorization or billing error"; Deny means no payment because the injury itself is not compensable (Rule 69L-7.710(1)).

The full code list, verbatim from Rule 69L-7.740(13)(b). There are 57 codes; numbers not shown do not exist.

CodeDescriptor (verbatim)Practice read
06Payment disallowed: location of service(s) is not appropriate for the level of service(s) billed.Place-of-service dispute.
10Payment denied: total denial: total compensability denied or the injury or illness for which service was rendered is not compensable.Compensability. Belongs with the worker's claim, not a reimbursement petition. The carrier must have issued a Notice of Denial (DWC-12).
11Payment denied: partial denial: diagnosis or procedure code for the line item service is not related to the compensable condition (insurer must specify the non-compensable condition).Check the accepted body part. The insurer must name the condition it excludes.
21Payment disallowed: medical necessity: medical records reflect no physician's order was given for service rendered or supply provided.Send the order.
22Payment disallowed: medical necessity: medical records reflect no physician's prescription was given for service rendered or supply provided.Send the prescription.
23Payment disallowed: medical necessity: diagnosis does not support the service rendered.Often a coding fix. If not, a medical-necessity petition with records.
24Payment disallowed: medical necessity: service rendered was not therapeutically appropriate.Medical necessity. Records plus practice parameters.
25Payment disallowed: medical necessity: service rendered was experimental, investigative or research in nature (insurer shall provide supporting documentation).The carrier owes you its evidence.
26Payment disallowed: service rendered by healthcare practitioner outside scope of practitioner's licensure.Licensure question.
30Payment disallowed: lack of authorization: no authorization given for service rendered or notice provided for emergency treatment pursuant to Section 440.13(3), F.S.Pull the written request and the carrier's response date. Section 2 decides it.
34Payment disallowed: no modification to the information provided on the medical bill. No payment made pursuant to contractual arrangement.A contract says zero. Ask which contract.
38Payment disallowed: insufficient documentation: documentation does not support this supply was dispensed to the patient.Documentation.
39Payment disallowed: insufficient documentation: documentation does not support this medication was dispensed to the patient.Documentation.
40Payment disallowed: insufficient documentation: documentation does not substantiate the service billed was rendered.Send the note. Resubmission is required by Rule 69L-7.730(1)(c).
41Payment disallowed: insufficient documentation: level of evaluation and management service not supported by documentation. (Insurer shall specify missing components of evaluation and management code description.)The insurer must say which components. If it did not, the code was misused.
42Payment disallowed: insufficient documentation: intensity of physical medicine and rehabilitation service not supported by documentation.Therapy documentation.
43Payment disallowed: insufficient documentation: frequency of service not supported by documentation.Frequency.
44Payment disallowed: insufficient documentation: duration of service not supported by documentation.Duration.
45Payment disallowed: insufficient documentation: fraud statement not provided pursuant to Section 440.105(7), F.S.Form defect. Fix and resubmit.
46Payment disallowed: insufficient documentation: required itemized statement not submitted with the medical bill.Attach and resubmit.
47Payment disallowed: insufficient documentation: invoice or certification not submitted for implant.Attach and resubmit.
48Payment disallowed: insufficient documentation: invoice not submitted for supplies.Attach and resubmit.
49Payment disallowed: insufficient documentation: invoice not submitted for medication.Attach and resubmit.
50Payment disallowed: insufficient documentation: specific documentation requested in writing at the time of authorization not submitted with the medical bill (insurers shall specify omitted documentation).Only valid if the carrier asked in writing at authorization (Rule 69L-7.740(2)(a)). Ask for that writing.
51Payment disallowed: insufficient documentation: required DFS-F5-DWC-25 not submitted.Attach the DWC-25.
52Payment disallowed: insufficient documentation: supply(ies) incidental to the procedure. (Incidental supply shall be specified.)The carrier must name the supply.
53Payment disallowed: insufficient documentation: required operative report not submitted with the medical bill.Attach and resubmit.
54Payment disallowed: insufficient documentation: required narrative report not submitted with the medical bill.Attach and resubmit.
58Payment disallowed: billing error: omitted or incorrect/invalid original manufacturer's NDC number.Dispensing. Rule note: a valid original NDC billed alone should be paid under code 98.
59Payment disallowed: billing error: omitted or incorrect/invalid repackaged NDC number.Dispensing.
60Payment disallowed: billing error: line item service previously billed and reimbursement decision previously rendered.Duplicate line. Find the first EOBR; its date started your 45 days.
61Payment disallowed: billing error: duplicate bill.Duplicate bill.
62Payment disallowed: billing error: incorrect procedure, modifier, units, supply code (insurer shall identify incorrect code).Corrected bill. The insurer must identify the code.
63Payment disallowed: billing error: service billed is integral component of another procedure code. (Shall specify inclusive procedure code).Bundling. Test it against the manual's own rules (section 1), not NCCI alone. The carrier must name the inclusive code.
64Payment disallowed: billing error: service "not reimbursable" under applicable workers' compensation reimbursement manual.Read the manual page the carrier relies on.
65Payment disallowed: billing error: multiple providers billed on the same form.Form defect.
66Payment disallowed: billing error: omitted procedure, modifier, units, or supply code.Corrected bill.
67Payment disallowed: billing error: Same service billed multiple times on same date of service.Units or modifier issue.
68Payment disallowed: billing error: Rental value has exceeded purchase price per written fee agreement.DME.
71Payment adjusted: insufficient documentation: level of evaluation and management service not supported by documentation.Downcoded E/M. Compare the note to the level's elements.
72Payment adjusted: insufficient documentation: intensity of physical medicine and rehabilitation service not supported by documentation.Therapy reduced.
73Payment adjusted: insufficient documentation: frequency of service not supported by documentation.Reduced.
74Payment adjusted: insufficient documentation: duration of service not supported by documentation.Reduced.
75Payment adjusted: insufficient documentation: specific documentation requested in writing at the time of authorization not submitted with the medical bill.As code 50, but partial.
80Payment adjusted: billing error: correction of procedure, modifier, supply code, units, or Original Manufacturer's NDC Number (shall identify correction).The carrier recoded you. Both codes must be shown (69L-7.740(8)). Recompute at the MRA of the billed code and decide whether to petition.
81Payment adjusted: billing error: payment modified pursuant to a charge audit.Ask for the audit.
83Payment adjusted: medical benefits paid apportioning out the percentage of the need for such care attributable to preexisting condition pursuant to Section 440.15(5)(b), F.S.Apportionment. The carrier had to tell you at authorization it would apportion (69L-7.740(2)(b)).
84Payment adjusted: co-payment applied pursuant to Section 440.13(13)(c), F.S.$10 post-MMI copay. Check MMI date and that it is an E/M visit.
85Payment adjusted: no modification to the information provided on the medical bill. Payment made pursuant to a letter of agreement between the health care provider and the carrier for a specific date of service or procedure.A one-off agreement. You should have a copy. Rule note: 85 may not be used in place of 93.
86Payment adjusted: billing error; repackaged medication; correction of NDC number dispensed or reimbursed pursuant to Section 440.13(12)(c), F.S. (insurer shall indicate the corrected NDC number dispensed or reimbursed).Dispensing. (The statute paragraph is now lettered (12)(h); the rule still prints (12)(c).)
90Paid: no modification to the information provided on the medical bill: payment made pursuant to Florida Workers' Compensation Health Care Provider Reimbursement Manual.Paid at the MRA. Verify the rate anyway.
91Paid: no modification to the information provided on the medical bill: payment made pursuant to Florida Workers' Compensation Reimbursement Manual for Ambulatory Surgical Centers.ASC manual.
92Paid: no modification to the information provided on the medical bill: payment made pursuant to Florida Workers' Compensation Reimbursement Manual for Hospitals.Hospital manual.
93Paid: no modification to the information provided on the medical bill: payment made pursuant to written contractual arrangement (network or PPO name required).The one to read closely. If the named network is one you never contracted with, or no network is named, the discount is disputable through the petition's contract question.
94Paid: Out-of-State Provider: payment made pursuant to the Out-of-State Provider section of the applicable Florida reimbursement manual.Locality 03 rate.
95Paid: Reimbursement Dispute Resolution: payment made pursuant to receipt of a Determination or Final order on a Petition for Resolution of Reimbursement Dispute, pursuant to Section 440.13(7), F.S.You won a petition.
96Paid: Payment made pursuant to a write-off by a health care provider self-insured employer.Self-insured employer write-off.
97Paid: no modification to the information provided on the medical bill; repackaged medication; reimbursed at repackaged methodology pursuant to Section 440.13(12)(c), F.S.Dispensing.
98Paid: no modification to the information provided on the medical bill; dispensed medication; billed original manufacturer's NDC number only; reimbursed pursuant to Section 440.13(12)(c), F.S.Dispensing.

Several descriptors carry a parenthetical duty on the insurer: "insurer must specify," "shall identify," "shall provide supporting documentation." An EOBR that uses one of those codes without the specification is defective on its face, and that goes in the petition.

6. The dispute: a petition to the Department, not an appeal to the carrier

There is no carrier appeal in Florida workers' comp. The statute gives the Department of Financial Services "exclusive jurisdiction to decide any matters concerning reimbursement" (§440.13(11)(c)), and by accepting workers' comp payment a provider "consents to the jurisdiction of the department" and agrees "to comply with any decision of the department" (§440.13(3)(f)). The mechanism is the petition for resolution of reimbursement dispute.

(a) Any health care provider who elects to contest the disallowance or adjustment of payment by a carrier under subsection (6) must, within 45 days after receipt of notice of disallowance or adjustment of payment, petition the department to resolve the dispute. The petitioner must serve a copy of the petition on the carrier and on all affected parties by certified mail. The petition must be accompanied by all documents and records that support the allegations contained in the petition. Failure of a petitioner to submit such documentation to the department results in dismissal of the petition.§440.13(7)(a)
(b) The carrier must submit to the department within 30 days after receipt of the petition all documentation substantiating the carrier's disallowance or adjustment. Failure of the carrier to timely submit such documentation to the department within 30 days constitutes a waiver of all objections to the petition.§440.13(7)(b)

Then the Department decides "within 120 days after receipt of all documentation" (§440.13(7)(c)), and if it finds the carrier wrong "the insurer shall reimburse the health care provider [...] within 30 days" (§440.13(7)(d)). The determination is made on the paper record: "the Petition Form, Response Form, and all supporting documentation" (Rule 69L-31.005(1)). Medical-necessity disputes go to an Expert Medical Advisor only when both sides submitted support.

The 45 days, exactly

The "notice of disallowance or adjustment" is the EOBR (Rule 69L-31.002(1)). The clock runs from the provider's receipt, and the rule is precise about how you prove it.

(b) The Health Care Provider must document receipt of the Notice of Disallowance or Adjustment by either: 1) using a date stamp that clearly reflects the date of receipt [...]; or 2) using a verifiable login process. [...] (c) If receipt cannot be established through a date stamp or verifiable login process, the Petitioner may provide a copy of the envelope [...] that clearly and legibly shows the postmark date, in which case receipt will be deemed to be five (5) calendar days after the postmark date. (d) If the Petitioner does not establish the date of its receipt [...] the Health Care Provider's receipt of the Notice of Disallowance or Adjustment will be deemed to be five (5) calendar days after the issue date on the Notice of Disallowance or Adjustment. An affidavit attesting to the date of receipt will not be accepted as proof of the date of receipt.Rule 69L-31.008(1)

So: date-stamp every EOBR on the day it arrives, or keep the portal login roster. Without one of those, the Department assumes you received it five days after the issue date, and no affidavit will move it. Timeliness is then measured by the day you submit: the USPS postmark, the common-carrier pick-up date, or hand delivery in Tallahassee on a weekday between 8 and 5 (69L-31.008(2), (4)). There is no electronic filing route in the rule.

The clock does not pause. "Time periods [...] are not tolled by any of the following actions: requesting an on-site audit; conducting an on-site audit; referral of the Health Care Provider for peer review consultation; or an independent medical examination of the injured employee" (69L-31.008(5)).

Service on the carrier: certified mail only

Service by delivery other than USPS certified mail or service by common carrier does not constitute service by USPS certified mail, as required by Section 440.13(7)(a), F.S., even if the Carrier's delivery and receipt of the documents are confirmed.Rule 69L-31.007(1)

FedEx and UPS do not count. Fax does not count. Serve the entity the EOBR names as the carrier's designee; if the EOBR names none, serve whoever issued it. Defective service gets a deficiency notice and 20 calendar days to cure, "or the petition will be dismissed with prejudice" (69L-31.007(2)). The carrier's 30 days start on the certified-mail receipt date (69L-31.008(3)).

What goes in the envelope

Only the official Petition Form is accepted: "The Department will not accept any other form or document in lieu of the Petition Form" (69L-31.003(2)). The current form is DFS-F6-DWC-3160-0023 (effective 07/2021), two pages, mailed to the Division of Workers' Compensation, Medical Services Section, 200 East Gaines Street, Tallahassee, Florida 32399-4232. The rule lists the attachments, and the form asks six questions that track them.

  1. Every EOBR in dispute, with proof of the receipt date (69L-31.003(3)(a)). Form question 1 asks how you prove receipt: date stamp, verifiable login, or postmark.
  2. Proof of certified-mail service on the carrier's designee, with the certified mail number (question 2).
  3. Your number. "What does the Petitioner assert is the correct reimbursement amount [...]? Attach to the Petition Form a detailed calculation" (question 3). Line by line, at the MRA or the contract rate.
  4. Every bill the carrier disallowed or adjusted (3)(b), and everything you sent with it (3)(c).
  5. The contract question (question 4, rule (3)(d)). If the carrier paid "pursuant to a contract," you must either show the contract and the provision the carrier underpaid, or show why the contract does not apply, or state on the form that no contract existed, or show the contract had ended. This is where code-93 discounts are contested.
  6. Documentation the carrier requested in writing at authorization, if any (question 5, tied to Rule 69L-7.730(1)(b)).
  7. Authorization. "Was the service(s) [...] authorized? [...] If authorization was obtained, provide a copy" (question 6, rule (3)(f)). For a medical-necessity dispute, the supporting records, plus an optional letter of medical necessity (3)(e).

An incomplete petition gets a deficiency notice and "twenty (20) calendar days from receipt of the notice of deficiency to cure," with proof of service of the cure on the carrier; miss it and "the petition will be dismissed with prejudice" (69L-31.003(4)). The form ends with a false-statement attestation under section 837.06. Sign it as the provider, or name the entity filing on the provider's behalf where the form allows.

One thing the form no longer asks: whether the services fall under a managed-care arrangement. The rule on managed-care arrangements, 69L-31.015, was repealed in 2014. Any checklist that still tells you to answer a managed-care question is out of date.

The carrier's response, and what a deficient one costs it

The carrier answers on its own form, DFS-F6-DWC-3160-0024, within 30 days, with "all supporting documentation" (69L-31.004(3)). If it used code 10 or 11, it must attach the Notice of Denial it sent the worker. If it disallowed for lack of authorization, it must produce its records showing it responded within the three-day or ten-day rule. It must serve the response on you "using a delivery method that provides confirmation of the date of delivery" (69L-31.004(4)). A deficient response gets 20 days to cure, and failing that "will constitute failure to submit requested documentation to the Department and a waiver of all objections to the petition" (69L-31.004(5)). The waiver rule in (7)(b) is the strongest default in any Florida payment regime. It only works if your petition was clean enough to survive its own deficiency review.

Which disputes are worth the envelope

Withdrawal is allowed at any time before a final hearing or final order (69L-31.013). What the corpus does not tell us: the window for requesting a hearing after an adverse determination. The statute and Rule 69L-31 are silent in the documents we hold, so we do not quote a number. Ask counsel before relying on one.

7. What a pattern of underpayment costs the carrier

(f) Any carrier that engages in a pattern or practice of arbitrarily or unreasonably disallowing or reducing payments to health care providers may be subject to one or more of the following penalties imposed by the department: 1. Repayment of the appropriate amount to the health care provider. 2. An administrative fine assessed by the department in an amount not to exceed $5,000 per instance of improperly disallowing or reducing payments. 3. Award of the health care provider's costs, including a reasonable attorney fee, for prosecuting the petition.§440.13(7)(f)

The phrase is "pattern or practice." A single petition rarely triggers it. A file of petitions against the same carrier, on the same code, with the same result, is how a practice makes the argument. That is a reason to keep petition outcomes in one place per carrier, not in individual patient charts. The symmetry is worth knowing too: a provider found to have a pattern of overutilization faces a bar from payment, deauthorization, and a $5,000 fine (§440.13(8)(b)), and an overpayment not refunded within 30 days of notice carries a penalty of up to $500 each (§440.13(11)(a)).

8. The market you are billing into

From the Office of Insurance Regulation's 2025 annual report (issued January 13, 2026), for calendar 2024:

The practice-level reading: carriers absorbed a mandated rate increase in a line that was already profitable and getting cheaper to write. The pressure to hold medical cost down lands on bill review. That is why the EOBR is worth reading line by line, and why the petition, filed cleanly and on time, is the practice's only lever that the carrier cannot ignore.

9. The operating checklist

  1. Every authorization request in writing, to the carrier, with the transmission record kept. Log date requested, date and form of response, carrier or designee name, and the person authorizing.
  2. Preliminary notice by the third business day after first treatment; full report within 15 days; DWC-25 only.
  3. Date-stamp every EOBR on arrival, or keep the portal login roster. Confirm the EOBR names the carrier's designee for service.
  4. Recompute every line against 175% or 210% of Medicare, or against the contract you can produce, on receipt. Flag codes 80, 81, 90, 93 that fall short and any code 63 the manual does not support.
  5. Calendar 45 days from receipt. Petition on the official form, all attachments, certified mail to the designee, before the window closes. Nothing tolls it.
  6. Track the carrier's 30 days from the certified-mail receipt. A late or deficient response is a waiver of all objections.
  7. Keep petition outcomes by carrier. A pattern is a penalty case.

Questions people ask

How much does Florida workers' comp pay a physician in 2026?

Section 440.13(12) sets the maximum reimbursement allowance at 175 percent of what Medicare allows for physician services and 210 percent for surgical procedures, or the 2003 panel level if greater. A carrier may pay a different amount only under a written contract with the provider. The percentages took effect January 1, 2025, according to the Office of Insurance Regulation's 2025 report.

How long does a Florida workers' comp carrier have to pay a medical bill?

Forty-five days from the date the carrier or its claim administrator received the bill, to pay, adjust, disallow, or deny it. The duty is in section 440.20(2)(b) and is implemented by Rule 69L-7.740(12). A deficient bill may instead be returned within 21 days with a written statement of the deficiency, but only on seven listed grounds.

How do I dispute a workers' comp underpayment in Florida?

By petition to the Department of Financial Services under section 440.13(7), on Form DFS-F6-DWC-3160-0023, within 45 days after receipt of the EOBR, with every supporting document attached and a copy served on the carrier's designee by USPS certified mail. There is no appeal to the carrier. The carrier then has 30 days to respond or it waives all objections.

What is the three-day rule in Florida workers' comp?

A carrier must respond to an authorization request by the close of the third business day after receipt. If it fails to respond to a written request for authorization for referral for medical treatment in that time, it consents to the medical necessity of the treatment. Specialist consultations, surgery, therapy, X-rays, and special diagnostic tests costing more than $1,000 need express authorization unless the carrier fails to respond within 10 days to a written request.

Can a Florida workers' comp carrier pay me a PPO discount rate?

Only under a written contractual arrangement, and the EOBR must name the network or PPO when it uses code 93. The reimbursement manual recognises only two bases for payment: an agreed contract price or the maximum reimbursement allowance. If you never contracted with the named network, dispute the line through the petition's contract question.

Can I bill the injured worker for the balance?

No. Section 440.13(13)(a) bars collecting a fee from an injured employee except as the chapter provides. The only exceptions are the $10 per-visit copayment after maximum medical improvement, which applies to evaluation and management visits only, and apportionment for a pre-existing condition where the carrier gave notice at authorization.

Sources

  1. Section 440.13, Florida Statutes (2025), Florida Senate print. Subsections (3), (4), (6), (7), (8), (11), (12), (13) as quoted.
  2. Rule 69L-7.740, Florida Administrative Code, Insurer Authorization and Medical Bill Review Responsibilities (History: New 2-18-16, amended 7-1-23).
  3. Rule 69L-7.710, F.A.C., Definitions (print current through June 24, 2025).
  4. Rule 69L-7.730, F.A.C., Health Care Provider Medical Billing and Reporting Responsibilities.
  5. Rule 69L-7.020, F.A.C., incorporating the Florida Workers' Compensation Health Care Provider Reimbursement Manual, 2024 Edition, effective January 1, 2025. Page cites are to the manual.
  6. Rule chapter 69L-31, F.A.C., Utilization and Reimbursement Dispute Rules (69L-31.002 through .013 as quoted; 69L-31.015 repealed 5-22-14).
  7. Form DFS-F6-DWC-3160-0023, Petition for Resolution of Reimbursement Dispute (effective 07/2021), and Form DFS-F6-DWC-3160-0024, Carrier Response (effective 07/2021).
  8. Florida Office of Insurance Regulation, 2025 Workers' Compensation Annual Report (issued January 13, 2026), pp. 2, 5, 8 to 10, 14 to 16, 19.
  9. Not in the documents we hold, and therefore not quoted: section 440.20 (the 45-day duty is cited through Rule 69L-7.740(12)); Rule 69L-24 (carrier audit penalties); the hearing-request window after a Department determination; the physician fee schedule tables themselves.

Related notes

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