Continuity of Care Service Requests - (UM-41) — um41-continuity-of-care-service-requests | CIGNA Coverage Update

Cigna modified UM-41 (Continuity of Care Service Requests), effective December 20, 2025. Here's what billing teams need to know about provider network exits and care transitions.

Cigna Healthcare updated policy UM-41 to clarify the process for evaluating Continuity of Care requests. This happens when a participating provider or facility leaves the Cigna network — or, in limited cases, when a client terminates its contract with Cigna. The policy does not list specific CPT, HCPCS, or ICD-10 codes. The coverage impact is broad: any patient mid-treatment with an out-of-network provider due to a network change may trigger this process.

Quick-Reference Table

Cigna Continuity of Care Coverage Policy: What UM-41 Actually Governs in 2025

UM-41 is Cigna Healthcare's internal utilization management policy governing Continuity of Care service requests. Think of it as the procedural rulebook that Cigna's care management team follows when a provider leaves the network and a patient has an active course of treatment.

The core trigger is a network disruption. A participating provider or facility exits the network. A patient is mid-treatment. The patient — or their treating provider — can submit a Continuity of Care request asking Cigna to allow care to continue with the now-out-of-network provider, typically at in-network benefit levels.

The second trigger is narrower: a client (an employer or plan sponsor) terminates its contract with Cigna. In limited circumstances, that disruption can also generate a Continuity of Care request. This is less common, but it matters if you manage billing for a self-funded employer plan.

This Cigna continuity of care coverage policy sets a consistent process for evaluating those requests and defines how Cigna responds. The modification on December 20, 2025 updates that process — and if your practice has had providers terminate Cigna participation or if you've seen mid-treatment patients caught in a network exit, this policy directly affects your reimbursement risk.

Cigna Continuity of Care Medical Necessity and Eligibility Requirements 2025

Continuity of Care requests are not automatic. Cigna evaluates each request against defined criteria. Medical necessity plays a central role in that evaluation.

A patient isn't automatically entitled to continued care with a departing provider. Cigna assesses whether the ongoing treatment represents a medically necessary continuation of an active course of care — not a new treatment episode, and not elective follow-up that could reasonably transfer to an in-network provider.

The coverage policy distinguishes between patients who are actively mid-treatment (think: ongoing chemotherapy, a third-trimester pregnancy, post-surgical recovery) versus patients who simply prefer a departing provider. Medical necessity documentation is the difference between an approved Continuity of Care request and a coverage gap.

Prior authorization requirements don't go away during a Continuity of Care period. If a service would normally require prior authorization from Cigna, it still requires prior authorization even if the Continuity of Care request is approved. This is a point where billing teams get tripped up — assuming an approved continuity request waives all other utilization management requirements. It doesn't.

Coverage Indications at a Glance

The policy does not list procedure-specific covered or non-covered indications. Coverage applies based on the circumstances of the network disruption and the patient's treatment status. The table below reflects the coverage framework UM-41 establishes.

Cigna Continuity of Care Billing Guidelines and Action Items 2025

This is where the rubber meets the road. A Continuity of Care approval changes how you bill — and billing errors during this period generate claim denial risk that is entirely avoidable.

1. Identify any providers in your group who are terminating Cigna participation before December 20, 2025.
Your credentialing and contracting team needs to run this list now. Any provider who exits the network without a patient-level Continuity of Care review in place creates a billing exposure for your practice. Patients and their care teams need time to initiate requests.

2. Flag active patients mid-treatment with any departing Cigna provider.
"Active mid-treatment" means an ongoing course of care — not a patient who had a visit six months ago. Think: active oncology patients, pregnant patients past 28 weeks, patients in active post-surgical recovery, patients with a chronic condition in active management. These are your Continuity of Care candidates.

3. Confirm that prior authorization requirements stay in force during the approved Continuity of Care period.
Do not assume a Continuity of Care approval from Cigna clears all utilization management requirements. Check each service line. If the procedure requires prior authorization under normal circumstances, get it — even during the continuity window.

4. Document medical necessity explicitly for every claim billed during a Continuity of Care period.
Cigna's evaluation of the request rests on medical necessity, and so does any retrospective review. Your documentation should clearly support that the care is a continuation of an active treatment course — not a new episode. Generic notes create claim denial risk. Specific, dated, condition-linked documentation protects reimbursement.

5. Confirm reimbursement terms before the continuity period begins.
An approved Continuity of Care request means the patient pays in-network cost-sharing. But the reimbursement rate your practice receives depends on the terms Cigna specifies in the approval. Don't assume you'll be paid at your former contracted rate. Confirm the rate in writing before the first claim goes out.

6. Update your billing team on the effective date of December 20, 2025.
Any patient situation that arises after the effective date of December 20, 2025 falls under the updated UM-41 process. Make sure your billing team and front desk staff know how to route Continuity of Care requests — delays in submitting requests cost patients in-network benefits and cost your practice clean claims.

7. Loop in your compliance officer if your practice has multiple providers leaving Cigna simultaneously.
A mass network exit — even if unintentional — creates layered Continuity of Care obligations and plan notification requirements. If that's your situation, talk to your compliance officer before the effective date. The exposure compounds quickly when multiple patients and multiple providers are involved at once.

CPT, HCPCS, and ICD-10 Codes for Continuity of Care Under UM-41

The UM-41 policy does not list specific CPT, HCPCS, or ICD-10 codes. This is by design. Continuity of Care is a process policy — it governs how Cigna handles requests across all services and specialties, not a specific procedure category.

Every code your practice bills during an approved Continuity of Care period is subject to UM-41's requirements. That includes evaluation and management codes, surgical codes, infusion codes, maternity codes, and any other billable service that was part of the patient's active course of treatment before the network disruption.

The absence of specific codes makes this policy broader — not narrower. Any claim billed against an approved Continuity of Care request carries the documentation and prior authorization requirements described above, regardless of the specific CPT or HCPCS code on the claim.

If your billing team needs guidance on how UM-41 applies to a specific code or service line, ask Cigna's provider relations team for written confirmation before billing. Don't interpret silence on codes as permission to bill freely.

Why This Policy Modification Matters More Than It Looks

A policy update on Continuity of Care processes sounds administrative. It isn't.

The real issue is claim denial exposure at the worst possible moment — when a provider is leaving the network and patient relationships are already disrupted. That's not a good time to discover your billing team didn't know the updated rules.

Continuity of Care billing sits at the intersection of utilization management, prior authorization, contract terms, and patient communication. Every one of those systems has to work correctly for the claim to pay. One gap — a missing prior auth, an undocumented medical necessity determination, a wrong reimbursement rate assumption — produces a denial you'll spend months fighting.

The December 20, 2025 modification to UM-41 updates the process Cigna uses to evaluate these requests. The billing implications flow from that process. Understand the process, and your billing guidelines follow naturally.