Florida Fee Schedule EMR: Why Medical-Only Claims Cost More

A medical-only claim still gets discounted on the experience modification rate (EMR, also called "the mod"). That doesn't mean it stopped mattering.

Florida fee schedule EMR pressure is showing up because the bill underneath the discount got larger. Enlyte's 2026 workers' compensation trend report says average recommended payment per Florida bill rose from $224 to $271 after the 2025 fee schedule change, a 21.1% increase (Enlyte, 2026). Gross savings fell from 58.0% to 49.4% in the same data set (Enlyte, 2026).

That is the piece contractors miss. The discount is applied after the claim value exists.

Florida Senate Bill 362 raised physician reimbursement from 110% to 175% of Medicare and surgical reimbursement from 140% to 210%, effective January 1, 2025 (Florida Senate, June 2024). The Florida Department of Financial Services lists the 2024 Health Care Provider Reimbursement Manual as effective January 1, 2025, with the 2025 fee schedule effective January 1, 2026 (Florida DFS, 2026).

Florida Fee Schedule EMR Math Starts With Paid Medical

The National Council on Compensation Insurance (NCCI) experience rating formula does not price the doctor visit directly. It starts with the losses reported by the carrier. Higher allowed medical payments become higher incurred losses on the worksheet.

The Experience Rating Adjustment (ERA) softens medical-only claims. In most NCCI states, ERA reduces medical-only losses by 70%, so 30% remains in the mod calculation (NCCI, 2023). But 30% of a larger bill is still a larger number.

Take the sample in the source hook. A $5,000 medical-only claim under the old fee schedule becomes about $6,055 if it rises by Enlyte's 21.1% payment change (Enlyte, 2026). After ERA, the ratable loss moves from $1,500 to roughly $1,817. Same injury. Same no-lost-time outcome. About $317 more enters the worksheet before the rest of the formula does its work.

That example isn't meant to predict every contractor's mod. NCCI does not publish this impact by trade, and the final mod depends on expected losses, class codes, payroll, weight, ballast, and each state's rating values. It does show the lever. When medical-only claim values rise, the primary loss loading rises with them.

Why A Discounted Claim Can Still Move The Mod

Medical-only claims are often treated like noise. On a clean account with high expected losses, one small claim may barely move the number. Florida construction accounts are different when payroll is concentrated in high-hazard classes and the experience period has only a few claims.

Small claims can matter because the mod formula gives more weight to primary losses than excess losses. Primary losses are the part of a claim treated as a frequency signal. A $6,055 medical-only claim is small enough that, after ERA, the ratable amount usually acts like primary loss rather than excess severity.

In our reviews of Southeast contractor worksheets, the problem is rarely one perfect sample claim. It's a cluster. Three medical-only claims that used to place $4,500 of ratable loss on a worksheet can place about $5,450 after a 21.1% medical payment lift. That is the contractor's own loss history getting heavier.

The WCRI Backdrop Is Not Reassuring

Workers Compensation Research Institute (WCRI) released its 2026 Florida CompScope findings on May 26, 2026. Total payments per claim in Florida rose about 5% per year from 2022 through 2025, with indemnity benefits driving much of the increase (WCRI, May 2026). WCRI also noted that total claim costs include medical payments, indemnity benefits, and benefit delivery expenses such as litigation and medical management (WCRI, May 2026).

That matters for 2027 renewals. The fee schedule change pushes nonhospital medical bills upward. Wage growth pushes indemnity benefits upward. Litigation keeps some claims open longer. The contractor sees the combined effect later, when the loss run feeds the NCCI worksheet.

Attorney involvement makes the Florida story harder. Prior Orson analysis covered the 41% claimant attorney involvement issue. Legal involvement does not enter the mod as a separate line item. It shows up through higher incurred values and longer claim tails.

What It Means For Construction Renewals

The filed-rate headline can hide this. Florida contractors can see rate decreases while their own mod rises. Those are not contradictory facts.

Rates are the statewide price basis. The mod is the account-specific multiplier. If your carrier reports higher medical-only values from the 2025 and 2026 fee schedule environment, the EMR can move before a CFO sees the full premium effect in a budget model.

That is why the $5,000 example matters. It is ordinary. A foreman gets imaging, therapy, and follow-up care, returns without indemnity, and the claim remains medical-only. Under the old fee schedule, the account got one worksheet value. Under the new schedule, it gets a higher value, even after the same ERA discount.

What An Audit Would Check

An audit checks whether Florida medical-only claims in the experience period are being valued consistently with the current fee schedule and whether the worksheet reflects the correct injury type treatment for ERA. It also checks whether open claim values have been updated after the January 1, 2025, reimbursement change and whether class codes match the work that produced the expected losses. The goal is not to fight the fee schedule. It is to make sure your mod is multiplying accurate data.

If your Florida construction renewal depends on a clean 2027 mod, send us your NCCI worksheet and we'll review the claim values before they become your renewal problem.