The California Medical Association (CMA) has learned that Cigna will delay implementation of its recently announced policy to require the submission of medical records with all Evaluation and Management (E/M) claims with CPT 99212-99215 and modifier 25 when a minor procedure is billed. 

CMA had serious concerns with Cigna’s policy change as it would result in significant, unnecessary administrative burden and compliance cost to physician practices, would disincentivize physicians from providing unscheduled services and would create duplicate requests thus wasting health care dollars. The policy also lacks clarity on product types impacted, is inconsistent with industry standards and CMS guidance, and appears to violate California law.

CMA and the American Medical Association reached out to Cigna regarding these serious concerns and urged the payor to rescind the policy. Due to this advocacy, Cigna has delayed implementation and the policy is under additional review. The reimbursement policy update therefore will not go into effect on August 13, 2022, as originally scheduled.

CMA believes a more collaborative approach to identify alternative methodologies for cost containment—including provider education on proper coding practices that do not bluntly penalize physicians using the modifier appropriately—will prove more effective and less costly in the long term. We will continue to work with Cigna to address our concerns and will provide updates as more information becomes available.

For more details, see CMA’s letter to Cigna that outlines our concerns with their new modifier 25 policy.