ASP Insight · State Regulatory · August 15, 2026

The answer up front: for calendar year 2026, the Texas Division of Workers' Compensation raised the Medical Fee Guideline conversion factor by 2.7%, following the annual adjustment methodology in 28 TAC §134.203, which indexes the Texas comp conversion factor to the Medicare Economic Index (MEI), not to Medicare's own conversion factor. The CMS 2026 Medicare Physician Fee Schedule conversion factor, by contrast, stayed flat. The result is a widening spread: the exact same CPT code now reimburses measurably more under Texas workers' comp than under Medicare, and any practice that default-prices comp claims at Medicare parity is quietly donating that spread back to carriers.

Why the two numbers diverge

Most people assume Texas comp simply rides Medicare. It does borrow Medicare's architecture, RVUs, CPT structure, and payment policies, but it deliberately does not borrow Medicare's conversion factor. That one design choice is the entire arbitrage.

The spread, visualized

Index both fee schedules to 100 at the start of 2026 pricing and the gap is immediate. This is not a rounding error. Compounded across every professional service line on every comp claim, it is a real revenue stream with a rule number attached to it.

Illustrative arithmetic applying the published 2.7% adjustment to a normalized $100 baseline. Your actual allowables come from the TDI-DWC fee schedule resources, which is exactly the point.

Where practices lose the spread

The leak is operational, not regulatory. Three failure modes show up over and over in comp AR:

1. The Medicare fee file is the default. Most practice management systems carry one expected-fee schedule per payer class, and comp gets mapped to the Medicare file because it is already loaded. Every 2026 comp remit that prices at the flat Medicare CF then passes the auto-adjudication check as "paid correctly" when it is actually underpaid against the DWC guideline.

2. Contracted networks anchor to the wrong baseline. Certified network and informal network agreements frequently express rates as a percentage of "the fee schedule." If your team reads that as the Medicare fee schedule instead of the DWC Medical Fee Guideline, the 2.7% adjustment never reaches your expected-payment logic.

3. Nobody reprices January-forward claims. The conversion factor adjustment applies to 2026 dates of service. Claims billed in early 2026 off a stale 2025 fee load, and remits auto-posted against them, will not flag a variance because both sides of the comparison are wrong.

The 2026 operating timeline

• Annually, per 28 TAC §134.203 DWC applies the MEI-based conversion factor adjustment to the Medical Fee Guideline. For 2026 that adjustment is +2.7%. This is automatic methodology, not a discretionary rate case, so it recurs every year.
• Calendar year 2026 dates of service The adjusted conversion factor governs professional services reimbursement for 2026 DOS. Expected-fee tables, contract crosswalks, and underpayment audit logic all need the new factor keyed by date of service, not posting date.
• Ongoing through 2026 Every comp remit should be audited against the DWC guideline rate. With Medicare's 2026 PFS conversion factor flat, any comp payment that matches your Medicare allowable to the penny is a red flag, not a clean payment.

Operator to-do list: capture the 2.7%

• 1Load a dedicated 2026 Texas DWC fee schedule into your PM system from the TDI-DWC fee schedule resources. Stop pointing comp payer plans at the Medicare fee file.
• 2Re-run expected reimbursement on all 2026-DOS comp claims already billed and paid. Flag every line where the allowed amount equals the flat Medicare rate.
• 3Pull your certified network agreements and confirm which fee schedule the contracted percentage anchors to. A percentage of the DWC guideline is worth 2.7% more in 2026 than a percentage of Medicare.
• 4Build the variance report by carrier. Systematic underpayment against the fee guideline is a dispute you document with 28 TAC §134.203 and the DWC-published factor, not with a phone call.
• 5Calendar the annual cycle. The MEI indexation repeats every year, so make the DWC conversion factor refresh a standing January fee-load task with an owner and a verification step.