When you use new advanced primary care management codes, your practice can get appropriate payment for complex care of Medicare beneficiaries. Like G2211, the APCM codes represent a recent effort from CMS to boost primary care.
APCM services are a new set of codes meant to provide payment for the resources associated with providing advanced primary care to patients. They bundle several existing care management and communication technology-based services, including:
APCM services may be reported monthly and are broken into three levels. The codes are:
Practices must satisfy several service elements to bill APCM services. Many service elements align with CCM and TCM.
At a high level, the service elements include:
For a full list of APCM requirements, visit the CMS APCM page.
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Patients don't need to receive all service elements each month. CMS anticipates that all APCM elements will be routinely provided, as deemed appropriate for each patient, but not all elements may be necessary for every patient during each month. Practices must maintain their ability to provide all elements to any patient in any given month.
Consent must be obtained before you start billing for APCM services for a patient. It only needs to be obtained once. It can be written or verbal but must be documented in the medical record. AAFP's FPM journal has a free sample consent form for APCM.
Consent must inform the patient that:
"We got data back that one patient had been to the ER more than 40 times in the year before, and it was always on a weekend. My care manager started calling him every Friday morning to ask, ‘Do you need to be seen? Do you need any refills?’ And like that, the following year, he went to the ER maybe twice.”
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APCM services can be billed once per calendar month. Only one physician or clinician can report APCM services for a patient per month.
Since APCM services represent a bundle of existing services (see above), the physician or clinician billing APCM cannot bill both APCM and the individual services for the same patient in the same month. For example, you may report either APCM or CCM for a patient, but you cannot report both for the same patient during the same month.
Additionally, a patient may receive CCM one month and APCM the next. However, it is important to note that the consent requirements for APCM and CCM are separate. Patient consent to receive CCM services does not satisfy the APCM consent requirement and vice versa.
APCM services can be billed by physicians, non-physician clinicians (e.g., nurse practitioners), physician assistants and clinical nurse specialists. Any specialty can bill APCM services, but they are aimed at primary care specialties.
By billing for APCM services, you are affirming that you are or intend to be responsible for all the patient’s primary care services and the focal point for all their needed health care services.
APCM services are designated as care management services, meaning they can be provided by auxiliary personnel under general supervision.
Yes, however, APCM, CCM and TCM may not be billed by the same physician or clinician for the same patient in a month. If a patient receiving APCM services qualifies for CCM or TCM in a month, the practice may choose which service they would like to report for the month.
| APCM | CCM | Key Difference |
| Billing Clinician | ||
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| Consent | ||
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| Initiating Visit | ||
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| Eligible Beneficiaries | ||
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| Time Threshold | ||
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| Access to Care and Care Continuity | ||
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| Comprehensive Care Management | ||
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| Patient-centered Comprehensive Care Plan | ||
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| Management of Care Transitions | ||
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| Practitioner, Home- and Community-based Care Coordination | ||
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| Enhanced Communication Opportunities | ||
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*—This element appears under Access and Continuity for CCM |
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| Patient Population-level Management | ||
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| Performance Measurement | ||
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Any patient may receive APCM services. There are three levels of APCM services. The level billed will depend on the number of chronic conditions a patient has (including none) and whether they are a Qualified Medicare Beneficiary (QMB). The three levels are:
The definition of a chronic condition aligns with definition used for CCM. The condition must be expected to last at least 12 months or until the death of the patient and place the patient at significant risk of death, acute exacerbation/decompensation or functional decline.
The QMB Program provides coverage of Medicare Part A and Part B premiums and cost-sharing to low-income beneficiaries. Individuals with QMB status cannot be billed for cost-sharing. Additional information related to the prohibition on billing QMBs can be found here.
There are several ways to verify whether an individual is a QMB, including:
Contact your Medicare Advantage plans to learn how to identify the QMB status of their members.
Coverage by private payers (including Medicare Advantage) and Medicaid varies. Check with your local provider relations representatives regarding their coverage.
The 2025 Medicare Physician Fee Schedule average national allowable amounts are:
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Yes, although it may be covered by a patient’s supplemental plan. As part of the consent process, you must ensure the beneficiary is aware that cost-sharing applies. Cost-sharing includes deductible, copay and coinsurance.
Practices participating in Primary Care First (PFC) and Making Care Primary (MCP) can report APCM services for the 2025 model year. The APCM services will be paid at the physician fee schedule rates (listed above).
APCM may be billed at any point during the calendar month. Practices will need to assess their billing workflows to determine how they would like to bill APCM services. As you review your workflow, you may want to consider:
No. CMS indicated in the 2025 Medicare Physician Fee Schedule Final Rule that billing for APCM services would be interpreted as an attestation that the service meets the requirements specified in the code descriptor.
CMS has not published detailed documentation guidance. While practices do not need to document that they meet the ACPM service capabilities, documentation should adequately reflect the applicable APCM services delivered to the patient during the month that APCM is billed (e.g., patient interactions with the care team, updates to the person-centered care plan, communications with other health care providers, etc.).
Care management is a foundational element of APCM services. If you're already providing chronic care management and transitional care management services, you likely have many APCM service elements already in place.
Review the APCM requirements and determine which elements require new workflows or whether you need to make modifications to your existing workflows. Make sure you obtain a separate consent for APCM, as separate consent for CCM and APCM services is required.
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