CMA asks Cigna to rescind burdensome modifier 25 policy

June 27, 2022
Area(s) of Interest: Payor Issues and Reimbursement 

The California Medical Association (CMA) is urging Cigna to rescind its recently announced policy that would 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. This change effectively penalizes physicians for providing efficient, unscheduled care to Cigna enrollees.

Cigna’s policy change 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 recently sent a letter outlining these concerns in detail and has asked the payor to rescind the policy before the August 13, 2022, effective date.

The new Cigna policy is overly broad, requiring all physicians billing for office visit codes 99212-99215 with modifier -25 and a minor procedure code to submit medical records as a precondition for payment. This creates yet another unnecessary administrative burden on physicians that are using the modifier appropriately.

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.

Practices with questions regarding this policy update can contact Cigna Customer Service at (800) 88Cigna (882-4462). 


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