NCMS is closely monitoring the August 15, 2026 implementation of Blue Cross and Blue Shield of North Carolina’s (BCBSNC) Evaluation and Management (E/M) Leveling Program and its potential impact on physicians and practices across the state.
BCBSNC has identified approximately 13% of its network providers for inclusion in the program, including physicians, physician associates (PAs) and nurse practitioners (NPs) across specialties. Letters to impacted providers were sent on July 27, 2026. Currently, the program is limited to office-based services (Place of Service 11) billed under E/M codes 99204, 99205, 99214 and 99215.
Under the program, BCBSNC may take one of three actions on an affected claim: pend the claim for further review, reimburse the service at a lower E/M level, or recoup payment through future reimbursements. When the program is applied, the provider’s payment remittance will include an EXCD code.
While the notification letter states the insurer will be using “an analytic solution to determine whether coding on these claims is aligned with national industry standard,” BCBSNC has indicated the process being used involves human review rather than AI. Providers who disagree with the determination will be directed to follow the health insurer’s standard claims dispute process.
What You Should Know: NCMS recognizes that changes to E/M claims review and reimbursement can create significant administrative and financial implications for physician practices. We encourage those who receive a notification letter to review it carefully, ensure documentation appropriately supports the E/M level billed, monitor remittance notices for EXCD codes, and track any claims that are reduced, pended or subject to recoupment.
NCMS will continue engaging BCBSNC on this issue, gathering feedback from the physician community and seeking additional clarity regarding implementation of the program. If your practice has received a notification letter or experienced a claim adjustment related to the E/M Leveling Program, we want to hear from you.
Please contact Jenni Hines at [email protected] to share your experience. Your feedback will help NCMS better understand the program’s impact on North Carolina physicians and inform our ongoing advocacy and education efforts.