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As you may be aware, several large health plans have implemented automatic downcoding programs that reduce physician reimbursement for services without prior review of medical records. Health plan automatic downcoding represents a clear violation of Colorado Division of Insurance Regulation 4-2-17 and a fundamental breach of the physician-payer relationship. These practices threaten the viability of physician practices, undermine patient access to care, and establish a "guilty until proven innocent" approach to claims adjudication that violates basic due process principles.
Physicians increasingly report issues with insurers using automated tools to downcode claims without clear justification. These policies reduce payment, threaten practice sustainability, and disproportionately affect physicians caring for patients with complex needs. Appeals can cost practices $40–$75 per claim, adding significant administrative burden.
The AMA has warned that policies like Cigna’s E/M “coding accuracy” review conflict with CPT guidelines, improperly rely on claim data rather than medical records, and lack transparency in how downcoding decisions are made. Such approaches discourage appropriate billing and increase friction between physicians and payers.
The Colorado Medical Society (CMS) has mounted a vigorous opposition to these illegal practices through all available means. As a first step, CMS has formally notified the Colorado Division of Insurance and sent letters to the health plans Aetna, Anthem, Cigna, and UnitedHealthcare that are currently engaging in automatic downcoding.
As this issue continues to develop, updates, resources, and next steps will continue to be posted on the CMS members-only resource page. A member login is required; username is the CMS member's email address or CMS member number. The password can be reset here. If you are a practice manager and need a login separate from your CMS-member physician, contact us at membership@cms.org. You may also relay any current experiences you are seeing to this same email address.
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