APCM services combine elements of several existing care management and communication technology-based services you may have already been billing for your patients. This payment bundle reflects the essential elements of advanced primary care, including:

• Principal Care Management (PCM) – disease-specific services to help manage a patient’s care for a single, complex chronic condition that puts them at risk of hospitalization, physical or cognitive decline, or death
• Transitional Care Management (TCM)
• Chronic Care Management (CCM)

Communication technology-based services include:

• Virtual check-ins
• Remote evaluations of pre-recorded patient information
• Interprofessional consultations

APCM services allow you to:

• Provide patients with a wide range of services to meet their individual needs based on complexity
• Bill for these services using a monthly bundle (instead of billing for each individual service or recording minute by minute)

These services help simplify your billing and documentation requirements while ensuring that your patients have access to high-quality primary care services.

Starting January 1, 2025, you can bill for APCM services if:

• You’re a physician or non-physician practitioner (NPP), including a nurse practitioner (NP), physician assistant (PA), or clinical nurse specialist (CNS)
• You’re responsible for all of your patient’s primary care services
• You’re the focal point for all of your patient’s needed health care services
• You’ve gotten either written or verbal consent from your patient

APCM service codes are primarily for primary care specialties, like general internal medicine, family medicine, geriatric medicine, or pediatrics.

You can bill for APCM services once per patient per calendar month. This helps remove some of the burden of billing with individual, time-based care management codes. 

Individual care management codes have time-based billing requirements, where you need to document every minute you spend on care management, and you must meet certain thresholds each month to bill those services. APCM services aren’t time based, and you can bill using an APCM HCPCS code once per month when you meet the billing requirements. 

The resources required to provide effective advanced primary care vary widely based on patient complexity, so choose the HCPCS code for APCM services that’s most appropriate for your patient’s medical and social complexity.

Use 1 of these 3 codes:

To bill for APCM services, you must complete these elements when they’re clinically appropriate for the individual patient (you don’t have to provide all of these services every month):

• Get patient consent. Get written or verbal consent from the patient to participate in APCM services, and document it in the patient’s medical record. The consent must inform your patient that:
  • Only 1 provider can furnish and be paid for APCM services during a calendar month
  • They have the right to stop services at any time
  • Cost sharing may apply to the patient

        Get consent before you start APCM services. You only need to get consent once.

• Conduct an initiating visit (paid separately) for new patients. You don’t need to conduct this visit if you or another provider in your practice have:

  • Seen the patient within the past 3 years
  • Provided another care management service (APCM, CCM, or PCM) to the patient within the past year

  The Medicare Annual Wellness Visit (AWV) may qualify as the initiating visit if the provider that will be responsible for providing APCM care performs the AWV 

• Provide 24/7 access and continuity of care, including:
  • 24/7 access for your patients or their caregivers with urgent needs to contact you or another member of the care team
  • Real-time access to the patient's medical information
  • The ability for the patient to schedule successive routine appointments with a designated member of the care team
  • Care delivery in alternative ways to traditional office visits, like home visits or expanded hours  
• Provide comprehensive care management, including:
  • Systemic needs assessments (medical and psychosocial) 
  • System-based approaches to ensure receipt of preventive services 
  • Medication reconciliation, management, and oversight of self-management
• Develop, implement, revise, and maintain an electronic patient-centered comprehensive care plan.
  • The care plan must be available within and outside the billing practice, as appropriate, to individuals involved in the patient's care
  • Members of the care team must be able to routinely access and update the care plan
  • You must also give a copy of the care plan to the patient or caregiver

• Coordinate care transitions between and among health care providers and settings, including:

  • Referrals to other providers
  • Follow-up after an emergency department visit
  • Follow-up after discharge from a hospital, skilled nursing facility (SNF), or other health care facility 

  Coordination of care transitions must include: 

  • Timely exchange of electronic health information with other health care providers
  • Timely follow-up communication (direct contact, phone, or electronic) with the patient or caregiver within 7 days of discharge from an emergency department visit, hospital, SNF, or other health care facility, as clinically indicated
• Coordinate practitioner, home-, and community-based care. You must provide ongoing coordinating communication and documentation on the patient’s psychosocial strengths, functional deficits, goals, preferences, and desired outcomes from practitioners, home- and community-based service providers, community-based social service providers, hospitals, SNFs, and others. 
• Provide enhanced communication opportunities. You must: 
  • Offer asynchronous, non-face-to-face consultation methods other than the phone, like secure messaging, email, internet, or a patient portal
  • Be able to conduct remote evaluation of pre-recorded patient information and provide interprofessional phone, internet, or electronic health record (EHR) referral services
  • Be able to use patient-initiated digital communications that require a clinical decision, like virtual check-ins, digital online assessment and management, and evaluation and management (E/M) visits (or e-visits) 
• Conduct patient population-level management. You must:
  • Analyze patient population data to identify gaps in care 
  • Risk stratify the practice population based on defined diagnoses, claims, or other electronic data to identify and target services to patients 
• Measure and report performance, including assessment of primary care quality, total cost of care, and meaningful use of Certified EHR Technology (CEHRT). You can either:
  • Report the Value in Primary Care MIPS Value Pathway (MVP). You’ll report performance starting in 2026 for CY 2025. 
  • Participate in a Medicare Shared Savings Program Accountable Care Organization (ACO), Realizing Equity, Access, and Community Health (REACH) ACO, Making Care Primary model, or Primary Care First model.

Yes, auxiliary personnel can provide APCM services incident to the professional services of the provider who bills the initiating visit (if required) and associated APCM services. APCM is a designated care management service, and auxiliary personnel will work under general supervision.

Auxiliary personnel means individuals who are supervised by physicians or other billing providers to perform services incident to professional services of the provider. They:

• Can be employees, leased employees, or independent contractors of the billing provider
• Must not have been excluded from Medicare, Medicaid, or other federally funded health care programs by the Office of the Inspector General or had their Medicare enrollment revoked
• Must meet any applicable requirements to furnish “incident to” services, including licensure, imposed by the State in which they provide the services

To learn more about APCM services, visit the CY 2025 Physician Fee Schedule Final Rule.