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Payer Reverses Course on Controversial Documentation Policy

Analysis  |  By Amanda Norris  
   May 31, 2023

Cigna is taking heed at its "burdensome" documentation requirement.

Just days before it was to take effect, Cigna announced it would delay implementation of a strict new policy requiring submission of office notes with all claims including evaluation and management (E/M) codes 99212, 99213, 99214, and 99215 and modifier -25 when a minor procedure is billed.

At the time, Cigna announced it would deny payment for these E/M services reported with modifier -25 if records documenting a significant and separately identifiable service are not submitted with the claim, and medical groups were quick to respond.  

For background, the revenue cycle coding staff report modifier -25 for E/M services on the same day of another service or procedure when it is performed by the same physician or provider.

The payer first unveiled the policy last summer, then postponed its activation after more than 100 medical associations said the policy would be too administratively burdensome and would negatively impact patient care.

The payer announced this year that it would go live with the policy on May 25. But on May 23, Cigna announced it would postpone the requirement, and did not supply a new implementation date. “Cigna will continue to review for future implementation,” the insurance company stated.

All this back and forth means that staying compliant with payers has been, and will continue to be, a burden on the revenue cycle workforce. With already strained staff it can be hard to find extra hands, and money, to keep up with payer requirements and policy changes.

“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. ”

Amanda Norris is the Associate Content Manager of Finance, Payer, Revenue Cycle, and Strategy for HealthLeaders.


Cigna said it would deny payment for certain services if documentation is not submitted with the claim, but it reversed course two days before the policy's implementation.

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