Aetna · Clinical coverage policy
Aetna Cervical Cancer Screening coverage criteria
Aetna CPB 0443 covers routine cervical cancer screening on age-based schedules - cytology every 3 years for women 21-29, and for women 30-65 either cytology every 3 years, hrHPV testing alone every 5 years, or co-testing every 5 years - plus more frequent screening for higher-risk groups (HIV, immunocompromised, DES-exposed, prior dysplasia/cancer) and diagnostic Pap smears tied to specific symptoms, malignancies, or risk factors. Screening is considered not medically necessary after total hysterectomy for benign disease, for women under 21, and (per USPSTF) for adequately screened low-risk women over 65; numerous newer/alternative screening technologies (e.g., AI-based screening, cervicography, optical/spectroscopy systems, various mRNA/methylation/FISH tests) are deemed experimental, investigational, or unproven.
Policy CPB 0443 · Effective · Verify against the current Aetna policy before submitting — view source policy.
Payer
Aetna
Policy
CPB 0443
Prior auth
Confirm
Effective
January 1, 2026
This page reflects the coverage criteria captured from Aetna policy CPB 0443 and may not include every criterion, exception, or code — verify the complete bulletin before submitting.
What this means for the claim
The covered path, the next step to get it approved, and the specific way it denies — built only from this policy.
When does Aetna cover Cervical Cancer Screening (CPT 88141), and what gets it denied?
- Path
- Aetna CPB 0443 covers routine cervical cancer screening on age-based schedules - cytology every 3 years for women 21-29, and for women 30-65 either cytology every 3 years, hrHPV testing alone every 5 years, or co-testing every 5 years - plus more frequent screening for higher-risk groups (HIV, immunocompromised, DES-exposed, prior dysplasia/cancer) and diagnostic Pap smears tied to specific symptoms, malignancies, or risk factors. Screening is considered not medically necessary after total hysterectomy for benign disease, for women under 21, and (per USPSTF) for adequately screened low-risk women over 65; numerous newer/alternative screening technologies (e.g., AI-based screening, cervicography, optical/spectroscopy systems, various mRNA/methylation/FISH tests) are deemed experimental, investigational, or unproven. Coverage criteria include: Women aged 21-29 years (non-hysterectomized): screening for cervical cancer every 3 years with cervical cytology alone (per USPSTF/ACOG).; Women aged 30-65 years (non-hysterectomized) - ONE of the following acceptable options: (a) screening every 3 years with cervical cytology alone; OR (b) every 5 years with high-risk human papillomavirus (hrHPV) testing alone; OR (c) every 5 years with hrHPV testing in combination with cytology (co-testing) (per USPSTF/ACOG).; Discontinuation of screening is appropriate after age 65 (or 70) in women with 3 or more negative consecutive tests and no cervical abnormalities during the previous 10 years.; HIV-infected women: Pap screening is considered medically necessary beginning in adolescence; per ACOG, cervical cytology screening twice in the first year after diagnosis and annually thereafter.; Sexually active immunocompromised adolescents (including organ transplant recipients and those on long-term steroids): screening after the onset of sexual activity (do not wait until age 21); testing at 6-month intervals during the first year of testing and then annually thereafter.; Women with a diagnosis of cervical dysplasia or cervical cancer: Pap screening is considered medically necessary beginning in adolescence, with testing twice in the first year after diagnosis and annually thereafter.; Sexually active women exposed in utero to DES (diethylstilbestrol): Pap smears considered medically necessary beginning in adolescence; testing should begin after the onset of sexual activity and be done at 6-month intervals during the first year of testing and then annually thereafter.; Post-treatment surveillance: women with histories of CIN grade 2, CIN grade 3, or cancer should undergo annual screening for 20 years after treatment.; Diagnostic Pap smears are medically necessary when ANY of the following apply: (a) Pap accompanied by a diagnosis of malignancy of the female genital tract (cervix, ovary, uterus, vagina); OR (b) description of symptoms/disease requiring diagnosis - ONE of: abnormal vaginal bleeding or discharge, chronic cervicitis, vaginal tumor; OR (c) following gynecological surgery for cancer; OR (d) DES exposure; OR (e) ANY of these risk factors: history of cervical/vaginal/vulvar cancer, HIV infection, history of genital HPV infection, immunosuppression, multiple sexual partners, previously abnormal Pap smear, previous STD.; Automated liquid-based thin-layer slide preparation (e.g., ThinPrep, SurePrep, AutoCyte PREP): medically necessary as an alternative to conventional Pap smears WHEN the criteria for conventional Pap smears are met.; Automated cervical cancer slide interpretation systems (e.g., FocalPoint, PAPNET): medically necessary as an adjunct to cervical cancer screening.; p16/Ki-67 dual staining: medically necessary for women with a positive HPV screening test.; Testing for high-risk strains of HPV DNA using FDA-approved techniques is medically necessary for ANY of the following: (a) hrHPV testing alone or co-testing every 5 years for non-hysterectomized women aged 30-65 for screening; (b) assessment of women with ASCUS; (c) follow-up of ASCUS-positive women with a prior positive HPV DNA test and negative colposcopy within 2 years; (d) follow-up of LSIL women with negative colposcopy within 2 years; (e) follow-up of ASC-H women with negative colposcopy within 2 years; (f) assessment of women with AGC NOS; (g) follow-up of AGC NOS women with negative colposcopy within 2 years.; The medically necessary indications for HPV DNA testing are not affected by pregnancy status.; An FDA-approved self-collected/self-sampling HPV test performed in a controlled, medical setting is an equally acceptable alternative to standard HPV tests collected with a speculum WHEN the criteria for hrHPV testing are met.; An FDA-approved at-home self-collected device (e.g., Teal Wand) is acceptable for hrHPV testing alone; for women aged 30 to 65 years who elect co-testing, the device may be used for hrHPV testing in combination with a separate clinician-collected cytology specimen every 5 years.. Applies to 30 codes: 88141, 88142, 88143, 88147, 88148, 88150, 88152, 88153, 88164, 88165, 88166, 88167, 88174, 88175, 87624, 87625, 87626, G0101, G0123, G0124, G0141, G0143, G0144, G0145, G0147, G0148, G0476, P3000, P3001, Q0091.
- Action
- Confirm prior-authorization status with Aetna before scheduling — it is code- and plan-specific, and this policy is not an exact authorization source.
- Trap
- Policy exclusions and limitations: Pap smear screening is considered not medically necessary for women who have undergone complete (total) hysterectomy for benign disease (e.g., no evidence of cervical neoplasia or cancer) or have absent cervix.; The USPSTF recommends against screening for cervical cancer in women older than 65 years who have had adequate prior screening and are not otherwise at high risk for cervical cancer.; Pap smear screening for all other women under 21 years of age, because it has no proven value for these younger women.; Aetna considers diagnostic Pap smears experimental, investigational, or unproven for all other indications (beyond the covered diagnostic indications listed).; Artificial intelligence-based cervical cancer screening - experimental, investigational, or unproven.; Cervicography or speculoscopy (Pap-Sure) for the screening or diagnosis of cervical cancer - experimental, investigational, or unproven.; DNA methylation as a triage marker for colposcopy referral in HPV-based cervical cancer screening - experimental, investigational, or unproven.; DYSIS Smart Colposcopy for screening and/or diagnosis of cervical cancer - experimental, investigational, or unproven.; Fluorescence in-situ hybridization (FISH) testing (e.g., the Ikonisys oncoFISH cervical test) for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; HPV testing as a primary screening test for cervical cancer in women younger than 30 years - experimental, investigational, or unproven.; HPV testing for selecting candidates for cervical cancer vaccine - experimental, investigational, or unproven.; HPV testing for members with definitively positive cervical cytology, other than follow-up of women with ASC-H, LSIL, or AGC NOS and negative colposcopy - experimental, investigational, or unproven.; HPV testing for low-risk HPV strains - experimental, investigational, or unproven.; HPV testing of men - experimental, investigational, or unproven.; HPV testing for indications other than detection of cervical cancer - experimental, investigational, or unproven.; HPV testing for girls and women less than 21 years of age, unless previous abnormal Pap - experimental, investigational, or unproven.; HPV testing for all indications other than those listed in the medically necessary section - experimental, investigational, or unproven.; PreTect HPV-Proofer / PreTect Proofer 7 HPV mRNA E6 and E7 Biomarker Test - experimental, investigational, or unproven.; QuantiVirus HPV E6/E7 mRNA test for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; Resolve laboratory testing kit for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; Spectroscopy / optical / optoelectric detection systems (e.g., Luma cervical imaging system, TruScreen) - experimental, investigational, or unproven.; Use of methylation markers for cervical cancer screening - experimental, investigational, or unproven.; Video colpography for cervical cancer screening or diagnosis - experimental, investigational, or unproven. Claims may be denied when the requested service falls under these. Some of these are conditional (note the stated exceptions) — confirm specifics against the bulletin.
Coverage criteria
- Women aged 21-29 years (non-hysterectomized): screening for cervical cancer every 3 years with cervical cytology alone (per USPSTF/ACOG).
- Women aged 30-65 years (non-hysterectomized) - ONE of the following acceptable options: (a) screening every 3 years with cervical cytology alone; OR (b) every 5 years with high-risk human papillomavirus (hrHPV) testing alone; OR (c) every 5 years with hrHPV testing in combination with cytology (co-testing) (per USPSTF/ACOG).
- Discontinuation of screening is appropriate after age 65 (or 70) in women with 3 or more negative consecutive tests and no cervical abnormalities during the previous 10 years.
- HIV-infected women: Pap screening is considered medically necessary beginning in adolescence; per ACOG, cervical cytology screening twice in the first year after diagnosis and annually thereafter.
- Sexually active immunocompromised adolescents (including organ transplant recipients and those on long-term steroids): screening after the onset of sexual activity (do not wait until age 21); testing at 6-month intervals during the first year of testing and then annually thereafter.
- Women with a diagnosis of cervical dysplasia or cervical cancer: Pap screening is considered medically necessary beginning in adolescence, with testing twice in the first year after diagnosis and annually thereafter.
- Sexually active women exposed in utero to DES (diethylstilbestrol): Pap smears considered medically necessary beginning in adolescence; testing should begin after the onset of sexual activity and be done at 6-month intervals during the first year of testing and then annually thereafter.
- Post-treatment surveillance: women with histories of CIN grade 2, CIN grade 3, or cancer should undergo annual screening for 20 years after treatment.
- Diagnostic Pap smears are medically necessary when ANY of the following apply: (a) Pap accompanied by a diagnosis of malignancy of the female genital tract (cervix, ovary, uterus, vagina); OR (b) description of symptoms/disease requiring diagnosis - ONE of: abnormal vaginal bleeding or discharge, chronic cervicitis, vaginal tumor; OR (c) following gynecological surgery for cancer; OR (d) DES exposure; OR (e) ANY of these risk factors: history of cervical/vaginal/vulvar cancer, HIV infection, history of genital HPV infection, immunosuppression, multiple sexual partners, previously abnormal Pap smear, previous STD.
- Automated liquid-based thin-layer slide preparation (e.g., ThinPrep, SurePrep, AutoCyte PREP): medically necessary as an alternative to conventional Pap smears WHEN the criteria for conventional Pap smears are met.
- Automated cervical cancer slide interpretation systems (e.g., FocalPoint, PAPNET): medically necessary as an adjunct to cervical cancer screening.
- p16/Ki-67 dual staining: medically necessary for women with a positive HPV screening test.
- Testing for high-risk strains of HPV DNA using FDA-approved techniques is medically necessary for ANY of the following: (a) hrHPV testing alone or co-testing every 5 years for non-hysterectomized women aged 30-65 for screening; (b) assessment of women with ASCUS; (c) follow-up of ASCUS-positive women with a prior positive HPV DNA test and negative colposcopy within 2 years; (d) follow-up of LSIL women with negative colposcopy within 2 years; (e) follow-up of ASC-H women with negative colposcopy within 2 years; (f) assessment of women with AGC NOS; (g) follow-up of AGC NOS women with negative colposcopy within 2 years.
- The medically necessary indications for HPV DNA testing are not affected by pregnancy status.
- An FDA-approved self-collected/self-sampling HPV test performed in a controlled, medical setting is an equally acceptable alternative to standard HPV tests collected with a speculum WHEN the criteria for hrHPV testing are met.
- An FDA-approved at-home self-collected device (e.g., Teal Wand) is acceptable for hrHPV testing alone; for women aged 30 to 65 years who elect co-testing, the device may be used for hrHPV testing in combination with a separate clinician-collected cytology specimen every 5 years.
Covered codes
Codes listed in this Aetna policy. Check each one's prior-authorization verdict and Medicare rate:
- 88141·PA verdict·Rate
- 88142·PA verdict·Rate
- 88143·PA verdict·Rate
- 88147·PA verdict·Rate
- 88148·PA verdict·Rate
- 88150·PA verdict·Rate
- 88152·PA verdict·Rate
- 88153·PA verdict·Rate
- 88164·PA verdict·Rate
- 88165·PA verdict·Rate
- 88166·PA verdict·Rate
- 88167·PA verdict·Rate
- 88174·PA verdict·Rate
- 88175·PA verdict·Rate
- 87624·PA verdict·Rate
- 87625·PA verdict·Rate
- 87626·PA verdict·Rate
- G0101·PA verdict·Rate
- G0123·PA verdict·Rate
- G0124·PA verdict·Rate
- G0141·PA verdict·Rate
- G0143·PA verdict·Rate
- G0144·PA verdict·Rate
- G0145·PA verdict·Rate
- G0147·PA verdict·Rate
- G0148·PA verdict·Rate
- G0476·PA verdict·Rate
- P3000·PA verdict·Rate
- P3001·PA verdict·Rate
- Q0091·PA verdict·Rate
Frequently asked questions
- When does Aetna cover Cervical Cancer Screening (CPT 88141), and what gets it denied?
- Aetna CPB 0443 covers routine cervical cancer screening on age-based schedules - cytology every 3 years for women 21-29, and for women 30-65 either cytology every 3 years, hrHPV testing alone every 5 years, or co-testing every 5 years - plus more frequent screening for higher-risk groups (HIV, immunocompromised, DES-exposed, prior dysplasia/cancer) and diagnostic Pap smears tied to specific symptoms, malignancies, or risk factors. Screening is considered not medically necessary after total hysterectomy for benign disease, for women under 21, and (per USPSTF) for adequately screened low-risk women over 65; numerous newer/alternative screening technologies (e.g., AI-based screening, cervicography, optical/spectroscopy systems, various mRNA/methylation/FISH tests) are deemed experimental, investigational, or unproven. Coverage criteria include: Women aged 21-29 years (non-hysterectomized): screening for cervical cancer every 3 years with cervical cytology alone (per USPSTF/ACOG).; Women aged 30-65 years (non-hysterectomized) - ONE of the following acceptable options: (a) screening every 3 years with cervical cytology alone; OR (b) every 5 years with high-risk human papillomavirus (hrHPV) testing alone; OR (c) every 5 years with hrHPV testing in combination with cytology (co-testing) (per USPSTF/ACOG).; Discontinuation of screening is appropriate after age 65 (or 70) in women with 3 or more negative consecutive tests and no cervical abnormalities during the previous 10 years.; HIV-infected women: Pap screening is considered medically necessary beginning in adolescence; per ACOG, cervical cytology screening twice in the first year after diagnosis and annually thereafter.; Sexually active immunocompromised adolescents (including organ transplant recipients and those on long-term steroids): screening after the onset of sexual activity (do not wait until age 21); testing at 6-month intervals during the first year of testing and then annually thereafter.; Women with a diagnosis of cervical dysplasia or cervical cancer: Pap screening is considered medically necessary beginning in adolescence, with testing twice in the first year after diagnosis and annually thereafter.; Sexually active women exposed in utero to DES (diethylstilbestrol): Pap smears considered medically necessary beginning in adolescence; testing should begin after the onset of sexual activity and be done at 6-month intervals during the first year of testing and then annually thereafter.; Post-treatment surveillance: women with histories of CIN grade 2, CIN grade 3, or cancer should undergo annual screening for 20 years after treatment.; Diagnostic Pap smears are medically necessary when ANY of the following apply: (a) Pap accompanied by a diagnosis of malignancy of the female genital tract (cervix, ovary, uterus, vagina); OR (b) description of symptoms/disease requiring diagnosis - ONE of: abnormal vaginal bleeding or discharge, chronic cervicitis, vaginal tumor; OR (c) following gynecological surgery for cancer; OR (d) DES exposure; OR (e) ANY of these risk factors: history of cervical/vaginal/vulvar cancer, HIV infection, history of genital HPV infection, immunosuppression, multiple sexual partners, previously abnormal Pap smear, previous STD.; Automated liquid-based thin-layer slide preparation (e.g., ThinPrep, SurePrep, AutoCyte PREP): medically necessary as an alternative to conventional Pap smears WHEN the criteria for conventional Pap smears are met.; Automated cervical cancer slide interpretation systems (e.g., FocalPoint, PAPNET): medically necessary as an adjunct to cervical cancer screening.; p16/Ki-67 dual staining: medically necessary for women with a positive HPV screening test.; Testing for high-risk strains of HPV DNA using FDA-approved techniques is medically necessary for ANY of the following: (a) hrHPV testing alone or co-testing every 5 years for non-hysterectomized women aged 30-65 for screening; (b) assessment of women with ASCUS; (c) follow-up of ASCUS-positive women with a prior positive HPV DNA test and negative colposcopy within 2 years; (d) follow-up of LSIL women with negative colposcopy within 2 years; (e) follow-up of ASC-H women with negative colposcopy within 2 years; (f) assessment of women with AGC NOS; (g) follow-up of AGC NOS women with negative colposcopy within 2 years.; The medically necessary indications for HPV DNA testing are not affected by pregnancy status.; An FDA-approved self-collected/self-sampling HPV test performed in a controlled, medical setting is an equally acceptable alternative to standard HPV tests collected with a speculum WHEN the criteria for hrHPV testing are met.; An FDA-approved at-home self-collected device (e.g., Teal Wand) is acceptable for hrHPV testing alone; for women aged 30 to 65 years who elect co-testing, the device may be used for hrHPV testing in combination with a separate clinician-collected cytology specimen every 5 years.. Applies to 30 codes: 88141, 88142, 88143, 88147, 88148, 88150, 88152, 88153, 88164, 88165, 88166, 88167, 88174, 88175, 87624, 87625, 87626, G0101, G0123, G0124, G0141, G0143, G0144, G0145, G0147, G0148, G0476, P3000, P3001, Q0091. Confirm prior-authorization status with Aetna before scheduling — it is code- and plan-specific, and this policy is not an exact authorization source. Policy exclusions and limitations: Pap smear screening is considered not medically necessary for women who have undergone complete (total) hysterectomy for benign disease (e.g., no evidence of cervical neoplasia or cancer) or have absent cervix.; The USPSTF recommends against screening for cervical cancer in women older than 65 years who have had adequate prior screening and are not otherwise at high risk for cervical cancer.; Pap smear screening for all other women under 21 years of age, because it has no proven value for these younger women.; Aetna considers diagnostic Pap smears experimental, investigational, or unproven for all other indications (beyond the covered diagnostic indications listed).; Artificial intelligence-based cervical cancer screening - experimental, investigational, or unproven.; Cervicography or speculoscopy (Pap-Sure) for the screening or diagnosis of cervical cancer - experimental, investigational, or unproven.; DNA methylation as a triage marker for colposcopy referral in HPV-based cervical cancer screening - experimental, investigational, or unproven.; DYSIS Smart Colposcopy for screening and/or diagnosis of cervical cancer - experimental, investigational, or unproven.; Fluorescence in-situ hybridization (FISH) testing (e.g., the Ikonisys oncoFISH cervical test) for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; HPV testing as a primary screening test for cervical cancer in women younger than 30 years - experimental, investigational, or unproven.; HPV testing for selecting candidates for cervical cancer vaccine - experimental, investigational, or unproven.; HPV testing for members with definitively positive cervical cytology, other than follow-up of women with ASC-H, LSIL, or AGC NOS and negative colposcopy - experimental, investigational, or unproven.; HPV testing for low-risk HPV strains - experimental, investigational, or unproven.; HPV testing of men - experimental, investigational, or unproven.; HPV testing for indications other than detection of cervical cancer - experimental, investigational, or unproven.; HPV testing for girls and women less than 21 years of age, unless previous abnormal Pap - experimental, investigational, or unproven.; HPV testing for all indications other than those listed in the medically necessary section - experimental, investigational, or unproven.; PreTect HPV-Proofer / PreTect Proofer 7 HPV mRNA E6 and E7 Biomarker Test - experimental, investigational, or unproven.; QuantiVirus HPV E6/E7 mRNA test for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; Resolve laboratory testing kit for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; Spectroscopy / optical / optoelectric detection systems (e.g., Luma cervical imaging system, TruScreen) - experimental, investigational, or unproven.; Use of methylation markers for cervical cancer screening - experimental, investigational, or unproven.; Video colpography for cervical cancer screening or diagnosis - experimental, investigational, or unproven. Claims may be denied when the requested service falls under these. Some of these are conditional (note the stated exceptions) — confirm specifics against the bulletin.
- Does Aetna require prior authorization for Cervical Cancer Screening?
- Confirm prior-authorization status with Aetna before scheduling — it is code- and plan-specific, and this policy is not an exact authorization source.
- What does Aetna exclude for Cervical Cancer Screening?
- Policy exclusions and limitations: Pap smear screening is considered not medically necessary for women who have undergone complete (total) hysterectomy for benign disease (e.g., no evidence of cervical neoplasia or cancer) or have absent cervix.; The USPSTF recommends against screening for cervical cancer in women older than 65 years who have had adequate prior screening and are not otherwise at high risk for cervical cancer.; Pap smear screening for all other women under 21 years of age, because it has no proven value for these younger women.; Aetna considers diagnostic Pap smears experimental, investigational, or unproven for all other indications (beyond the covered diagnostic indications listed).; Artificial intelligence-based cervical cancer screening - experimental, investigational, or unproven.; Cervicography or speculoscopy (Pap-Sure) for the screening or diagnosis of cervical cancer - experimental, investigational, or unproven.; DNA methylation as a triage marker for colposcopy referral in HPV-based cervical cancer screening - experimental, investigational, or unproven.; DYSIS Smart Colposcopy for screening and/or diagnosis of cervical cancer - experimental, investigational, or unproven.; Fluorescence in-situ hybridization (FISH) testing (e.g., the Ikonisys oncoFISH cervical test) for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; HPV testing as a primary screening test for cervical cancer in women younger than 30 years - experimental, investigational, or unproven.; HPV testing for selecting candidates for cervical cancer vaccine - experimental, investigational, or unproven.; HPV testing for members with definitively positive cervical cytology, other than follow-up of women with ASC-H, LSIL, or AGC NOS and negative colposcopy - experimental, investigational, or unproven.; HPV testing for low-risk HPV strains - experimental, investigational, or unproven.; HPV testing of men - experimental, investigational, or unproven.; HPV testing for indications other than detection of cervical cancer - experimental, investigational, or unproven.; HPV testing for girls and women less than 21 years of age, unless previous abnormal Pap - experimental, investigational, or unproven.; HPV testing for all indications other than those listed in the medically necessary section - experimental, investigational, or unproven.; PreTect HPV-Proofer / PreTect Proofer 7 HPV mRNA E6 and E7 Biomarker Test - experimental, investigational, or unproven.; QuantiVirus HPV E6/E7 mRNA test for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; Resolve laboratory testing kit for cervical cancer screening or diagnosis - experimental, investigational, or unproven.; Spectroscopy / optical / optoelectric detection systems (e.g., Luma cervical imaging system, TruScreen) - experimental, investigational, or unproven.; Use of methylation markers for cervical cancer screening - experimental, investigational, or unproven.; Video colpography for cervical cancer screening or diagnosis - experimental, investigational, or unproven. Claims may be denied when the requested service falls under these. Some of these are conditional (note the stated exceptions) — confirm specifics against the bulletin.
Source
Aetna CPB 0443 — Cervical Cancer ScreeningRelated
- All Aetna coverage policies
- Aetna prior-authorization requirements — which codes need PA, by CPT
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This page summarizes Aetna clinical-coverage criteria extracted from policy CPB 0443 for educational purposes. Coverage policies change and vary by individual plan. Always verify against Aetna's current policy before performing a procedure or submitting a claim. d3rx is not responsible for claim denials or reimbursement issues.