ACA Opposes Provider, Patient Burdens from Cigna Modifier 25 Policy

Arlington, Va. – The American Chiropractic Association (ACA) has joined with more than 100 other healthcare organizations to oppose a new policy by Cigna Healthcare that creates an undue administrative burden for providers when submitting evaluation and management (E/M) claims with modifier 25, and that could potentially lead to more hassle and costs for patients.

At issue is a new rule, set to go into effect on May 25, 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. Cigna has provided no data or rationale to support the change, leading the healthcare organizations to question its intent and to propose alternative action.

In a recent letter to Cigna CEO David Cordani, the groups stated, “Our organizations are alarmed at the significant administrative burdens and costs for healthcare professionals – and Cigna – that will result from implementation of this policy. By bluntly requiring clinical documentation for all claims for an E/M service reported with modifier 25, physicians and other providers will be forced to submit an enormous number of office notes, and Cigna will be deluged with medical records.”

The groups – which include the American Medical Association (AMA), the American Academy of Family Physicians, and the American Nurses Association – propose instead that Cigna 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.

“The Cigna policy would not only add to providers’ already significant administrative burden, but it could potentially negatively impact patients by preventing them from promptly getting the medically necessary care they need or forcing them to incur added co-pay costs by requiring them to access that care on a different day,” noted Kris Anderson, DC, MS, ACA advisor to the AMA RUC Healthcare Professionals Advisory Committee (HCPAC).

As outlined in Current Procedural Terminology (CPT®), modifier 25 enables reporting of a significant, separately identifiable E/M service by the same physician or other healthcare professional on the same day of a procedure or other service. According to the letter to Cigna, “[B]y facilitating the provision of unscheduled, medically necessary care, modifier 25 supports prompt diagnosis and streamlined treatment.” It goes on to state that the new policy “creates disincentive for physicians and other healthcare professionals to provide unscheduled services.”
To read the joint letter to Cigna in full, visit the ACA website at

About the American Chiropractic Association

The American Chiropractic Association (ACA) is the largest professional chiropractic organization in the United States. ACA attracts the most principled and accomplished chiropractors, who understand that it takes more to be called an ACA chiropractor. We are leading our profession in the most constructive and far-reaching ways—by working hand in hand with other health care professionals, by lobbying for pro-chiropractic legislation and policies, by supporting meaningful research and by using that research to inform our treatment practices. We also provide professional and educational opportunities for all our members and are committed to being a positive and unifying force for the practice of modern chiropractic. To learn more, visit