When Cigna Healthcare's R49 policy made headlines in October 2025, many assumed it was an isolated case. Cigna Healthcare then paused the policy due to regulatory pressure. The relief was short-lived. The trend didn't stop; it had already spread to nearly every major insurer in the country.
On October 1, Cigna Healthcare implemented its new R49 policy, introducing more stringent medical complexity criteria for Evaluation and Management (E/M) code reimbursement. For most practices, it may seem like business as usual.
Claims are still going out the door. Documentation is still being entered, and nothing unusual has appeared on your remittance reports.
But here's the catch: downcoding has already started.
Oct 35 min read
In fact, one healthcare provider we worked with achieved 132% of monthly collection goals.