The Power of Unified Objection in Action

For a second time, Cigna has postponed implementation of a controversial policy “requiring all providers to submit office notes with all claims including E/M codes 99212, 99213, 99214, and 99215 and modifier 25 when a minor procedure is billed.”¹ The American Chiropractic Association and 100-plus other health care organizations voiced opposition to the new policy, penning a joint letter to the Cigna CEO earlier this year.²

Cigna originally introduced the policy in May 2022, but after receiving initial pushback, delayed implementation, reintroducing the policy in March 2023 with an implementation date of May 25, 2023.³ The insurer announced it would postpone implementation again only days before the policy would have taken effect,^3-4 noting the following:

Notification: Cigna will delay the implementation to require the submission of documentation to support the use of modifier 25 when billed with E/M CPT codes 99212-99215 and a minor procedure. Cigna will continue to review for future implementation.⁵

In the letter to Cigna CEO David Cordani, the organizations, including allopathic heavyweights such as the American Medical Association, American Academy of Family Physicians, and American Nurses Association, explained their objection to the policy:

“We urge Cigna to reconsider this policy due to its negative impact on practice administrative costs and burdens across medical specialties and geographic regions, as well as its potential negative effect on patients, and instead partner with our organizations on a collaborative educational initiative to ensure correct use of modifier 25.”

They also offered Cigna a solution, as explained in the ACA release: “conduct targeted outreach to select providers who may have ‘unexpected coding patterns’ and collaborate with healthcare organizations on education programs to support the correct use of modifier 25.”

Because modifier 25 is used to report a significant, separately identifiable E/M service on the same day of another service, the organizations emphasized in their letter to the Cigna CEO that the new policy would create “disincentive for physicians and other healthcare professionals to provide unscheduled services”; while noting the value of modifier 25: “[By] facilitating the provision of unscheduled, medically necessary care, modifier 25 supports prompt diagnosis and streamlined treatment – which in turn promotes high-value, high-quality, and patient-centric care.”

References

1. ACA Opposes Provider, Patient Burdens From Cigna Modifier 25 Policy.” American Chiropractic Association, May 18, 2023.
2. Letter to Cigna CEO / Chairman David Cordani, dated April 18, 2023.
3. Emerson J. “Cigna Delays Implementation of Modifier 25 Policy Again.” Becker’s Payer Issues, May 23, 2023.
4. Cigna Postpones Implementation of Modifier 25 Policy.” Press release, American Chiropractic Association, May 24, 2023.
5. Reimbursement Policy: Modifier 25 – Significant, Separately Identifiable Evaluation and Management Service by the Same Physician on the Same Day of the Procedure or Other Service.” Cigna, Policy #M25.