ACOI Works to Address Proposed Regence BlueCross Blue Shield Modifier 25 Policy

Following advocacy by the American Osteopathic Association (AOA), ACOI, and other osteopathic organizations, Regence BlueCross Blue Shield announced a pause in implementation of its proposed Modifier 25 reimbursement policy set to take effect on September 1, 2026.

Following comments received from the AOA, ACOI, and others, Regence announced it would pause implementation of the modifier 25 proposed rule to review the potential for unintended consequences for patient care and physician practices. In announcing the pause, the company announced plans to conduct further review and evaluate potential refinements.  You may view a copy of the letter sent to Regence here.

Under the paused proposed policy, evaluation and management (E/M) services appended with modifier 25 would not have been separately reimbursed when performed on the same day as a minor procedure solely based on the existence of a prior face-to-face E/M visit for the same diagnosis within the proceeding 60 days.  The proposal would have inappropriately shifted reimbursement determinations from being based upon clinical work performed on the date of service to a retrospective utilization history.  This is inconsistent with established CPT and Centers for Medicare and Medicaid Services (CMS) National Correct Coding Initiative (NCCI) guidance.  ACOI will continue to monitor this and other issues that risk appropriate compensation for physicians and access to needed care.