TL;DR: Cigna Healthcare modified MM 0565, its prescription digital therapeutics coverage policy, effective December 16, 2025. All three HCPCS codes currently addressed by this policy — E0738, E0739, and E1905 — carry an Experimental, Investigational, and Unproven designation. Here's what that means for your billing team right now.


Cigna Healthcare updated MM 0565, the Cigna prescription digital therapeutics coverage policy, with an effective date of December 16, 2025. The policy governs FDA-required prescription digital therapeutics (PDTs) — software-based interventions delivered via mobile apps, wearable devices, and digital platforms for adult and pediatric patients. The three HCPCS codes in scope, E0738, E0739, and E1905, are all classified as Experimental, Investigational, and Unproven (EIU). If your team bills any of these codes to Cigna, the denial risk is high and immediate.


Quick-Reference Table

Field Detail
Payer Cigna Healthcare
Policy Prescription Digital Therapeutics
Policy Code MM 0565
Change Type Modified
Effective Date December 16, 2025
Impact Level High — all listed codes classified as EIU
Specialties Affected Physical medicine & rehabilitation, neurology, behavioral health, psychiatry
Key Action Flag E0738, E0739, and E1905 in your charge capture as non-covered under Cigna before December 16, 2025

Cigna Prescription Digital Therapeutics Coverage Criteria and Medical Necessity Requirements 2025

Under MM 0565, Cigna defines a prescription digital therapeutic as a software-based intervention that meets three specific criteria. It must require a prescription from a licensed healthcare provider. It must hold FDA approval or clearance. And its safety and effectiveness must be supported by published, peer-reviewed clinical evidence for treating, managing, or preventing a specific disease or disorder.

That last requirement carries real weight. Cigna isn't just asking whether the FDA cleared a device — it wants published peer-reviewed evidence of clinical benefit. General wellness apps, fitness platforms, and tools used solely to inform, monitor, or diagnose a condition don't qualify as PDTs under this coverage policy. They aren't treating a disease, so they're out of scope.

Components covered under a PDT may include devices, accessories, software, smartphone apps, and other elements needed to deliver the therapy. The policy applies to both adult and pediatric populations, which is broader than many payers allow in the PDT space.

Here's the problem: despite setting up that criteria framework, Cigna classifies all three HCPCS codes currently assigned to PDT services — E0738, E0739, and E1905 — as Experimental, Investigational, and Unproven. That means even if a product meets every definition in the policy, Cigna is not covering it under these codes right now. Medical necessity criteria exist on paper, but reimbursement under MM 0565 isn't happening through these three codes at this time.

If you're billing for prescription digital therapeutics and relying on Cigna reimbursement, this policy is a hard stop. Before the effective date of December 16, 2025, talk to your compliance officer about how this affects your revenue cycle for any PDT services in your patient mix.


Cigna Prescription Digital Therapeutics Exclusions and Non-Covered Indications

MM 0565 draws a clear line between PDTs and general digital health tools. Cigna explicitly excludes several categories from coverage consideration under this policy.

Software programs used for general health promotion, wellness, or fitness don't qualify as PDTs. Neither do tools used solely to inform, monitor, or diagnose — even if they're software-based and clinician-ordered. The policy is explicit: if the tool doesn't treat a disease, it's not a PDT.

Digital therapeutics that don't require a prescription are also outside the scope of MM 0565. Those products may go through separate benefit determination, but this policy doesn't govern them. Don't assume a non-prescription DTx product is covered just because a related PDT might be.

The three HCPCS codes in this policy carry the EIU designation, which is Cigna's way of saying the evidence base doesn't yet meet its clinical coverage standards — regardless of FDA status. FDA clearance alone does not trigger Cigna coverage. That distinction matters when patients ask whether their PDT device is "approved." FDA-approved and Cigna-covered are two different things.

Prior authorization is unlikely to unlock reimbursement when the underlying code is designated EIU. Sending a prior auth request for E0738, E0739, or E1905 under Cigna will almost certainly result in a denial. Don't waste your team's time on prior authorization submissions for these codes until Cigna changes the coverage position.


Coverage Indications at a Glance

Indication Status Relevant Codes Notes
Upper extremity rehabilitation via active assistance system Experimental, Investigational, Unproven E0738 Not covered regardless of medical necessity documentation
Rehabilitation with interactive interface and active assistance Experimental, Investigational, Unproven E0739 Not covered; EIU designation applies
Virtual reality cognitive behavioral therapy (VR-CBT) device with preprogrammed therapy software Experimental, Investigational, Unproven E1905 FDA-cleared products included; Cigna coverage position is still EIU

This policy is now in effect (since 2025-12-16). Verify your claims match the updated criteria above.

Cigna Prescription Digital Therapeutics Billing Guidelines and Action Items 2025

The practical impact of this policy update is straightforward, but the operational steps take time to execute. Act before December 16, 2025.

#Action Item
1

Flag E0738, E0739, and E1905 in your charge capture system as non-covered under Cigna. Add a hard stop or warning that triggers when any of these codes are attached to a Cigna payer. Claim denial is the outcome if this doesn't happen before the effective date.

2

Audit claims in progress for Cigna patients receiving PDT services. If you have pending claims or expected submissions using E0738, E0739, or E1905, pull them now. Submitting these codes after December 16, 2025 without a coverage exception documented is a denial waiting to happen.

3

Review any active prior authorization approvals tied to these codes. A prior auth approval issued before the policy change doesn't guarantee payment after it. Check with your Cigna provider rep about whether existing auths are honored post-effective date.

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One additional note on prescription digital therapeutics billing broadly: this space is evolving fast. CMS hasn't established a clear national coverage determination for PDTs, and Cigna's EIU position reflects where most commercial payers currently sit. Don't build your revenue model around PDT reimbursement from Cigna — or most major commercial payers — until coverage positions change.


Sample Version Diff Line-by-line changes
Previous VersionCurrent Version
Coverage is considered experimental and investigational for all indicationsCoverage is considered medically necessary when specific criteria are met
Prior authorization is not requiredPrior authorization is required for initial treatment
Documentation must include clinical historyDocumentation must include clinical history
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CPT, HCPCS, and ICD-10 Codes for Prescription Digital Therapeutics Under MM 0565

Not Covered / Experimental Codes

All three HCPCS codes under MM 0565 carry the Experimental, Investigational, and Unproven designation. None are covered under Cigna's current prescription digital therapeutics coverage policy.

Code Type Description Reason
E0738 HCPCS Upper extremity rehabilitation system providing active assistance to facilitate muscle re-education Experimental, Investigational, Unproven
E0739 HCPCS Rehabilitation system with interactive interface providing active assistance in rehabilitation therapy Experimental, Investigational, Unproven
E1905 HCPCS Virtual reality cognitive behavioral therapy (CBT) device, including preprogrammed therapy software Experimental, Investigational, Unproven

Key ICD-10-CM Diagnosis Codes

The policy data does not list specific ICD-10-CM codes. MM 0565 does not tie coverage criteria to specific diagnosis codes — the EIU designation applies across all indications for these HCPCS codes.


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