UnitedHealthcare Releases Site of Services Medical Policies in First Quarter 2025
(March 21, 2025) – UnitedHealthcare has released three policies that have steadily implemented new Site of Service requirements, moving services out of hospitals and into alternative settings for ambulatory surgery, infusion drug delivery, colonoscopies, and, most recently, imaging services. These policies are:
Mandatory Site of Service policies are of concern to providers because they:
- Affects patient access to services, particularly at a time when there are already lengthy waitlists
- Require providers to spend crucial time making a clinical argument for why services should be covered in a hospital setting
- Disrupt continuity of care and force patients to travel long distances to facilities that may have no affiliation with the clinicians caring for the patient
- Constitutes a misrepresentation that frustrates patients who assumed they could receive services at their local hospital
- Unintended consequences that limit access to care, such as nursing homes that are already in short supply, are now expected to transport patients longer distances
Additionally, on Feb. 1, 2025, UHC began requiring a GA modifier on claims for commercial plan members as an addition to consent requirements under its "Charging Members for non-covered services protocol." According to providers, this policy:
- It places an enormous administrative burden on providers and their staff to predict, prior to rendering a service, whether it may or may not be covered and provide the member with a detailed account of what might be covered and what that service would cost
- Restricts a provider's ability to bill for services rendered when they are denied by a carrier
- Conflates services that are not within the scope of coverage and for which the health plan has no standing (e.g. A cosmetic procedure) with a medical necessity denial
If you have any questions, please contact Shannan Flach at sflach@kha-net.org.
--Shannan Flach