May 30, 2023

APMA joined with AMA and other specialty medical societies to submit a comment letter regarding Cigna’s modifier 25 policy. In the comment letter, we asked CIGNA to immediately rescind its policy requiring submission of office notes with all claims including evaluation and management (E/M) Current Procedural Terminology (CPT®) codes 99212, 99213, 99214, and 99215 and modifier 25 when a minor procedure is billed. While we have not received a formal reply from Cigna, we have received information that Cigna is preparing to announce a delay in implementing its updated modifier 25 policy. The policy pertains to the submission of documentation required to support the use of modifier 25 when billed with E/M CPT codes 99212–99215 and a minor procedure.

The primary reason behind Cigna's decision to delay the implementation of the modifier 25 policy is to reevaluate the reimbursement policy update. This step will allow Cigna to optimize the provider experience and undertake additional provider education in collaboration with key national medical associations. By doing so, Cigna aims to ensure that modifier 25 is used appropriately and in alignment with national guidelines and industry standards.

Although a new implementation date has not been communicated yet, Cigna assures its stakeholders that they appreciate their partnership and patience during this process. Cigna looks forward to working more collaboratively with provider partners, medical associations, and their membership to enhance the understanding and utilization of modifier 25.

For more information regarding the 25 modifier, please visit www.apma.org/25modifier.

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