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 |
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. |
| 4 | Update patient financial counseling scripts for PDT services. If your practice offers virtual reality CBT (E1905), upper extremity rehabilitation systems (E0738), or interactive rehab systems (E0739), patients need to know Cigna won't cover these under current billing guidelines. Set the expectation before the service, not after the denial. |
| 5 | Document the FDA-approval and peer-reviewed evidence status for any PDT products you're using. Even though E0738, E0739, and E1905 are currently EIU, Cigna's policy framework suggests coverage could open up when the evidence base strengthens. Build your documentation practice now so you're ready if coverage positions shift. |
| 6 | If your volume of PDT services is significant, loop in your compliance officer before December 16, 2025. This policy affects revenue cycle planning for any practice billing prescription digital therapeutics. The EIU designation on all three codes has cash flow implications that go beyond a single billing edit. |
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.
| Previous Version | Current Version |
|---|---|
| Coverage is considered experimental and investigational for all indications | Coverage is considered medically necessary when specific criteria are met |
| Prior authorization is not required | Prior authorization is required for initial treatment |
| Documentation must include clinical history | Documentation must include clinical history |
| Re-review every 24 months | Re-review every 12 months with updated clinical documentation |
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.
Get the Full Picture
Track this policy across versions, search 1,500+ policies by CPT code, and get real-time alerts when any payer changes coverage.