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APMA Urges Regence to Rescind Modifier 25 Policy

  • Jul 20, 2026

As part of APMA’s efforts to ensure fair reimbursement and financial security for podiatric physicians, the association sent a letter to Regence opposing a new reimbursement policy affecting both commercial and Medicare Advantage plans that would impact members in Idaho, Oregon, Washington, and Utah. Effective September 1, the policy would deny payment for certain evaluation and management (E&M) services billed with Modifier 25 when they are performed on the same day as a surgical procedure with a 0- or 10-day global period, if the provider billed an E&M with the same diagnosis code within the previous 60 days.

In its letter, APMA explains that the policy is inconsistent with CPT and National Correct Coding Initiative (NCCI) guidance, which recognize that a significant, separately identifiable E&M service may be reported on the same day as a procedure when supported by appropriate documentation. APMA also notes that the determining factor is the work performed and documented, instead of whether the patient had a prior E&M visit for the same diagnosis.

Members can read all APMA comment letters at www.apma.org/commentletters.