CMA calls on physicians to speak out against Cigna’s unlawful downcoding policy
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September 04, 2025


What You Need to Know: CMA is urging physicians and medical groups to contact Cigna and demand the withdrawal of its new automatic downcoding policy. The policy appears to violate California law, undermines nationally recognized coding standards, and creates unnecessary administrative burdens.

The California Medical Association (CMA) is urging physicians and medical groups to reach out to Cigna and share their concerns about the insurer’s new “Evaluation and Management Coding Accuracy” reimbursement policy, scheduled to take effect on October 1, 2025. The policy would allow Cigna to automatically downcode higher-level Evaluation and Management (E/M) services whenever it determines the encounter criteria on a claim does not support the level billed.

Physicians who dispute these downcoding decisions would be forced to file an appeal and submit supporting medical records via fax, creating substantial costs for both physicians and the plan itself. 

CMA has cautioned Cigna that this policy appears to violate state law, creates unnecessary administrative burdens, and fails to align with nationally recognized standards. “Rather than improving accuracy, this policy functions as a barrier to appropriate reimbursement and adds wasteful administrative costs to both practices and Cigna,” CMA said in a letter to the insurer.

CMA believes that more constructive approaches—such as targeted provider education and outreach to outliers—would better achieve coding accuracy while preserving physician time for patient care.

CMA has formally called on Cigna to rescind the policy and will continue to advocate aggressively to protect physicians from unlawful downcoding practices. The American Medical Association recently sent a letter to Cigna, to express their strong concerns with the policy as well.

Call to Action

CMA is urging physicians and medical groups to also make their concerns known directly to Cigna. Please contact Cigna Customer Service at (800) 88-Cigna (882-4462) or via the provider portal and request that the company rescind the R49 downcoding policy.

When contacting Cigna, emphasize the following key points:

  • The policy lacks transparency and fails to disclose claims adjudication criteria.
  • It conflicts with AMA and CMS E/M coding guidelines.
  • It risks violating California’s claims payment and disclosure laws.
  • It will increase administrative burdens and costs for both practices and the insurer.

CMA has also prepared talking points practices can use when communicating with Cigna on this issue.

 

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