The California Medical Association (CMA) has submitted a letter in strong opposition to Cigna’s decision to re-release its costly, burdensome modifier 25 policy. The policy – Modifier 25-Significant, Separately Identifiable Evaluation and Management Service by the Same Physician on the Same Day of the Procedure or Other Service – will 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. It is scheduled to become effective nationwide on May 25, 2023.

This is the same policy introduced last year, but after significant opposition from CMA, the American Medical Association (AMA), and other state and specialty societies, Cigna rescinded the announced policy, advising CMA that it would likely be subject to various modifications before being reintroduced. Unfortunately, aside from adding an email option for submission of medical records, the policy appears to mirror the same policy released in 2022.

This policy change will result in significant, unnecessary administrative burdens and compliance costs to physician practices, effectively penalizes physicians for providing efficient, unscheduled care to Cigna enrollees, and is inconsistent with California law.

CMA, AMA and others in organized medicine continue to have significant concerns with this policy. We believe 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.

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

Practices with questions or concerns are encouraged to contact Cigna Customer Service at (800) 88Cigna (882-4462).