APMA submitted a letter to Cigna calling on it to withdraw its Evaluation and Management Coding Accuracy Policy (R49), scheduled for implementation on October 1, 2025. The new policy would automatically downcode higher-level E/M claims based on diagnosis codes instead of physician documentation. This would directly conflict with federal rules and AMA CPT guidance.
If implemented, Cigna's policy would place significant new administrative burdens on practices, threaten reimbursement stability, and reduce patient access to necessary podiatric care. Vulnerable populations, including those with diabetes and vascular disease, would be especially affected.
APMA is urging Cigna to collaborate with medical associations, target outliers rather than all providers, and publish transparent guidelines. APMA stands ready to work with Cigna to ensure coding accuracy is strengthened without undermining patient care.
Read APMA's comment letters at www.apma.org/CommentLetters. Contact the APMA Advocacy Department with any questions or concerns.