Advocacy in action AOA works to reduce administrative burden and protect patient care
The AOA advocates with private payers to decrease administrative burden for physicians, streamline payment of claims and improve outcomes for patients. Working on behalf of the nation’s 207,000+ DOs and medical students, the AOA physician services team engages with healthcare payers when policies delay or deny patient care, create added administrative work or otherwise hinder efficient healthcare delivery.
If you are an AOA member in need of assistance, contact our Physician Services team by email or call (312) 202-8000. If your AOA membership is not current and you wish to take advantage of this and all other AOA member benefits, you may join or renew your membership online.
Insurer policies that may impact DOs
Modifier 25
Insurers continue to target claims involving Modifier 25 with policies that trigger automatic audits, some may be based on the diagnosis and time between claims, others are based strictly on the use of the modifier. Other denials may be for prepayment clinical validation for a range of modifiers. AOA works closely with members experiencing increased denials or payment delays.
Downcoding
Insurers are implementing policies that automatically reduce (downcode) E/M claims when the reported service level is deemed higher than supported by the diagnosis or documentation. These edits often rely on algorithms that review claim details and may result in payment reductions or denials. The AOA works closely with members experiencing increased downcoding, denials or payment delays to address these challenges.
Aetna
The Physician Services Team meets with Aetna annually to learn about new policies, or as warranted to express concerns from members.
Aetna Provider Newsletters
Anthem
The Physician Services Team meets with Anthem monthly to learn about new policies and to express concerns from members.
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The Blue Plans
Blue Shield of California
- June 2024 | Following advocacy efforts by the AOA/AOiA Physician Services Team, the AOA has been informed by Blue Shield of California (BSC) that they have rescinded the recently announced update to their Global Surgical Period Payment Policy. The policy would have reduced their reimbursement by 50% for evaluation and management (E&M) services appended with modifier 25 and billed along with minor procedure codes that have a global period of 0-10 days, like osteopathic manipulative treatment (OMT). This advocacy win is due to joint efforts in the form of a letter sent by the AOA, AOA Physician Services and the Osteopathic Physicians & Surgeons of California (OPSC) on behalf of its physician and student members
- May 2024 | Global Surgical Period Policy effective date of service on or after July 14, 2024, when certain office or other outpatient visit E/M procedures (CPT codes: 92002, 92004, 92012, 92014 and 99201-99215) appended with Modifier 25 are billed appropriately during the minor (0- or 10-day) by the same specialty physician and/or other healthcare professional performing the 0/10 day global procedure, Blue Shield of California will reimburse the E/M services at 50% of the Blue Shield Provider Allowance.
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Florida Blue
Blue Cross Complete of Michigan
- April 2025 | Use new telemedicine codes, starting July 1, 2025
If rendering a virtual E/M service that’s audio-only or audio-video, don’t submit claims for these services using E/M codes 99202-99205 or 99212-99215 with the telemedicine place of service codes or modifiers. The claims processing systems will be updated to deny these E/M codes when billed with any telemedicine place of service or modifiers as provider liable effective July 1, 2025.
- Dec. 2023 | Update on Chiropractic and Osteopathic Manipulation benefits
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BlueCross BlueShield of North Carolina
- June 2024 | Effective June 27, 2024, Blue Cross and Blue Shield of North Carolina (Blue Cross NC) has made the decision to rescind the reimbursement policy for evaluation and management (E&M) services with a fifty percent (50%) reduction when performed by the same provider/group practice on the same day as a minor procedure. This decision to rescind is applicable to all lines of business, including Commercial, Host, State Health Plan (SHP), Federal Employee Program (FEP) and Medicare Advantage. The above update is in reference to this previously posted Provider News.
- May 2024 | Effective Sept. 1, 2024, Blue Cross and Blue Shield of North Carolina (Blue Cross NC) will begin reimbursing evaluation and management services at fifty percent (50%) when performed by the same provider/group practice on the same day as a minor procedure. This policy update applies to Commercial, Host, State Health Plan (SHP), Federal Employee Program (FEP) and Medicare Advantage.
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HCSC (includes Blue Cross Blue Shield of Illinois, Montana, New Mexico, Oklahoma and Texas)
Horizon Blue
Highmark BlueCross BlueShield
- Aug. 2025 | Following advocacy efforts by the AOA/AOiA Physician Services Team, effective Sept. 1, 2025, Highmark’s List of Procedures/DME Requiring Authorization, which had inclusion of OMT codes (98925-98929) prior (dated back to CY2024), have been updated to reflect no prior authorization is required for OMT codes across all regions (Pennsylvania, West Virginia, Delaware and New York). All OMT claims denied for prior authorization can be resubmitted for adjudication. If you continue to have denials, please contact AOA Physician Services immediately.
BlueCross BlueShield of Massachusetts
- Nov. 2025 | Following advocacy efforts by the AOA/AOiA Physician Services Team and the Massachusetts Osteopathic Society (MOS), BCBSMA replied that the program will target only providers with unusually high rates of high-level E/M coding (“outliers”), not the majority of network providers. Claims from these providers will be reviewed, and if overcoding is found, payments may be reduced. Providers can appeal decisions, and those no longer considered outliers will be removed from the program after periodic review.
- Aug. 2025 | BCBSMA Evaluation and Management Overcoding Program: Effective Nov. 3, 2025, BCBSMA will expand their pre-payment claims editing to review professional services for evaluation and management (E/M) overcoding. They will assess Level 4 and 5 E/M codes to determine if the level of service billed is appropriate for the severity of the members’ condition as reported in the claim. If they identify overcoding, they may adjust reimbursement to a lower-level E/M. The AOA sent a letter formally opposing this program, urging BCBSMA to reconsider.
Regence
- March 2025 | Following advocacy efforts by the AOA/AOiA Physician Services Team, along with AAO, ACOFP, IOPA, OPSO, UOMA and WOMA, The Bulletin announced that Regence has decided not to implement changes to its Modifier 25; Significant, Separately Identifiable Service (Modifier #103) and Global Days (Administrative #101) reimbursement policies at this time.
- Dec. 2024 | The Bulletin states for services delivered on or after March 1, 2025, when modifier 25 is appended to an E&M service (CPT 92002, 92004, 92012, 92014, 99202-99205, 99211-99215) delivered on the same date as a minor procedure (i.e., services with a global surgery indicator of 00 or 10) performed by the same provider, we will reduce E&M reimbursement by 50% to offset the redundant practice expenses.
- Aug. 2024 | The Connection announced postponing updates to the Modifier 25; Significant, Separately Identifiable Service (Modifier #103) and Global Days (Administrative #101) reimbursement policies. They had previously announced in the June 2024 issues of The Bulletin and The Connection that they would update these policies effective Sept. 1, 2024. Look for more information in the Oct. 2024 issues of The Bulletin and newsletter.
- June 2024 | Effective Sept. 1, 2024. When Modifier 25 is appropriately appended to an evaluation & management (E&M) service and is submitted on the same date of service as a minor procedure, by the same physician or other qualified healthcare provider, the E&M service will be reimbursed at 50% of the allowed amount. Regence announced change to their Global Days #101 and Modifier 25 #103 reimbursement policies but has not been updated as of yet.
AOA Physician Services communicated with Regence and Cambia (Regence parent company) leadership regarding customer service issues and various reimbursement policies, especially related to denials for E&M with OMT services. Regence responded that appealed claims have a 3.4% overturn rate and that they have adjusted their claim editing process, beginning in 2022, which demonstrates less overall impact to providers. Regence confirmed that changes were made in their customer service department that hopefully result in better provider experience. The AOA will continue to aggressively pursue Regence action. If you are still having customer service issues with Regence, please let Physician Services know. Studies show that 65% of denied claims annually do not get appealed. We strongly encourage physicians to appeal against all claims.
Premera
- May 2023 manipulation services: In the osteopathic manipulative treatment section, added that an assessment is considered part of the manipulation procedure code. Also added reference to the CMS National Physician Fee Schedule stating that the OMT codes are classified as minor procedures.
- Osteopathic Manipulations: We limit osteopathic manipulative therapy to one manipulation code, per provider, per patient, per day. A new patient Evaluation and Management (E&M) code will be reimbursed consistent with the new/established patient guidelines. All E&M services billed on the same day as an osteopathic manipulation will be reimbursed when billed consistent with Modifier 25 payment policy if the E&M service represents a service above and beyond the usual preservice/post service work associated with the osteopathic service. Documentation must support the use of Modifier 25.
- Jan. 2023 E&M Visit: Added third paragraph to indicate that the appending of Modifier 25 is not a guarantee of payment. Added the last paragraph in the policy to indicate appending Modifier 25 to the E&M must be documented in the notes as a separate and distinct E&M service.
- March 2022 Modifier 25 Policy Updates: Added clarification on the correct use of Modifier 25 on evaluation and management (E&M) services indicating that appending Modifier 25 does not result in automatic reimbursement unless supported by the documentation in the member’s medical record as a separately identifiable service.
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Cigna
The Physician Services Team meets with Cigna annually to learn about new policies, or as warranted to express concerns from members.
- July 2025 | Cigna Evaluation and Management Coding Accuracy Reimbursement Policy (R49): Effective Oct. 1, 2025, Cigna may adjust E/M CPT codes—specifically 99204-99205, 99214-99215 and 99244-99245—downward by one level if the submitted claim does not meet the criteria for the higher-level code. The AOA has sent a letter formally opposing this policy, urging Cigna to reconsider. As of November 2025, Cigna has only acknowledged receipt of our letter, and that the policy has been implemented.
- Following advocacy efforts by the AOA/AOiA Physician Services Team, the AMA and impacted specialties, Cigna announced that it delayed the implementation of their reimbursement policy requiring the submission of office notes with claims submitted with E/M codes 99212-99215 and modifier 25 when a minor procedure is billed. The policy was scheduled to take effect on Aug. 13, 2022, and again on May 25, 2023. While Cigna remains committed to ensuring appropriate usage and reporting of Modifier 25, they have acknowledged that the policy does not comply with clean claims laws in 24 states. Cigna has not provided a new potential implementation date for the policy.
- Official Cigna Notification Banner: 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.
- Modifier 25 Reimbursement Policy: Modifier 25 – Significant, Separately Identifiable Evaluation and Management Service by the Same Physician on the Same Day of the Procedure or Other Service
- Cigna Evaluation & Management Coding Program
- Cigna Information to Establish Medical Necessity
- Cigna Provider Newsletters
Humana
The Physician Services Team meets with Humana semiannually to learn about new policies or sooner if warranted to express concerns from members.
Registration Humana Newsletter
UnitedHealthcare
The Physician Services Team meets with UHC monthly to learn about new policies and to express concerns from members.
The AOA has joined the multi-organizational sign-on letter (172 national and state medical specialty societies, patient organizations, foundations, physician groups, hospitals and industry) to UHC asking them not to implement the United Healthcare’s (UHC) gastrointestinal (GI) endoscopy prior authorization program.
Registration UHC Email Briefs
MVP Healthcare
- July 2025 | Following advocacy efforts by the AOA/AOiA Physician Servies Team, MVP Healthcare has officially revised their Payment Policy, confirming that OMT will be covered for all DOs and MDs without any limitations, exclusions or prior authorization requirements. This advocacy win is due to joint efforts in the form of a letter sent by the AOA, AOA Physician Services, the American Academy of Osteopathy (AAO), the New York State Osteopathic Medical Society (NYSOMS) and the Vermont State Assn of Osteopathic Physicians and Surgeons (VSAOPS) on behalf of its physician and student members.