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APCM vs CCM: What's the Difference? Medicare Guide for 2026

Compare Advanced Primary Care Management and Chronic Care Management in 2026, including G0556, G0557, G0558, CCM CPT codes, time requirements, patient eligibility, care plans, consent, staffing, and Medicare billing differences.

Updated for 2026. Advanced Primary Care Management (APCM) and Chronic Care Management (CCM) both support longitudinal Medicare care, but they use very different billing models.

CCM is primarily a time-based care-management service for patients with two or more qualifying chronic conditions. APCM is a broader monthly primary-care bundle that incorporates elements of CCM, Principal Care Management (PCM), Transitional Care Management (TCM), and several communication technology-based services.

For practices evaluating Medicare care-management programs in 2026, understanding the differences between APCM and CCM can help with patient selection, staffing, documentation, technology, and billing workflows.

APCM vs CCM at a Glance

FeatureAPCMCCMFull nameAdvanced Primary Care ManagementChronic Care ManagementBilling modelMonthly bundled servicePrimarily time-based monthly serviceMinute-by-minute thresholdNoYes for major CCM codesMain codesG0556, G0557, G055899490, 99439, 99491, 99437, 99487, 99489Primary-care responsibilityBilling practitioner must be responsible for primary care and serve as continuing focal pointCCM may be furnished by an eligible practitioner managing the patient's chronic conditionsPopulation-level managementRequired practice capabilityNot a defining CCM billing elementPerformance measurementRequiredNot a defining CCM billing elementComprehensive care planRequired as clinically appropriateCore CCM requirementPatient consentWritten or verbalWritten or verbal

What Is Advanced Primary Care Management?

CMS introduced Advanced Primary Care Management services beginning January 1, 2025.

APCM combines elements of multiple existing Medicare services into one monthly primary-care bundle, including:

  • Chronic Care Management
  • Principal Care Management
  • Transitional Care Management
  • Virtual check-ins
  • Remote evaluation of prerecorded patient information
  • Interprofessional consultation services

Unlike traditional CCM, APCM does not require the practice to reach a specific minute threshold each month before reporting the monthly APCM code.

What Is Chronic Care Management?

CCM is a Medicare care-management program for patients with two or more chronic conditions expected to last at least 12 months, or until death, and that place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline.

Most CCM billing pathways are based on documented monthly time.

Common CCM codes include:

  • 99490 – first 20 minutes of clinical-staff CCM
  • 99439 – additional 20-minute clinical-staff CCM periods
  • 99491 – first 30 minutes personally performed by a physician or qualified healthcare professional
  • 99437 – additional 30-minute practitioner CCM periods
  • 99487 – first 60 minutes of Complex CCM
  • 99489 – additional Complex CCM time

The Biggest Difference: Bundled vs Time-Based Billing

For many practices, the most important APCM vs CCM difference is how the monthly service is measured.

CCM

CCM codes generally require the practice to track qualifying minutes throughout the calendar month.

For example, CPT 99490 begins with the first 20 minutes of qualifying CCM work.

APCM

CMS states that APCM is not time based. Instead of recording enough minutes to meet a monthly threshold, the practice bills the appropriate APCM code once per patient per calendar month when applicable requirements are satisfied.

This can reduce some of the administrative burden associated with minute-by-minute care-management billing.

2026 APCM Codes

CMS uses three APCM HCPCS codes representing different patient complexity levels.

CodePatient LevelKey RequirementG0556Level 1Lower-complexity APCM population; practitioner is responsible for primary care and serves as continuing focal pointG0557Level 2Patient has 2 or more qualifying chronic conditionsG0558Level 3Patient is a Qualified Medicare Beneficiary with 2 or more qualifying chronic conditions

G0557 Eligibility

For HCPCS G0557, CMS requires two or more chronic conditions that:

  • Are expected to last at least 12 months or until the patient's death
  • Place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline

These chronic-condition criteria are similar to Medicare's CCM eligibility framework.

What Is G0558?

G0558 is the highest APCM level among the three base codes.

CMS requires that the patient:

  • Have two or more qualifying chronic conditions
  • Meet the applicable duration and clinical-risk requirements
  • Have Qualified Medicare Beneficiary status

The QMB requirement is what specifically distinguishes G0558 from G0557.

Who Can Bill APCM?

CMS states that APCM may be billed by an eligible physician or non-physician practitioner, including certain:

  • Physicians
  • Nurse practitioners
  • Physician assistants
  • Clinical nurse specialists

The billing practitioner must be responsible for the patient's primary care services and act as the continuing focal point for all needed health care services.

CMS notes that APCM codes are primarily intended for primary-care specialties such as family medicine, internal medicine, geriatrics, and pediatrics.

Who Can Bill CCM?

Eligible physicians and certain qualified non-physician practitioners may bill CCM when applicable requirements are met.

CCM is often delivered in primary care, but eligible specialists may also furnish CCM when they are appropriately managing the patient's chronic conditions.

This makes CCM potentially more flexible than APCM for certain specialty-driven care-management models.

APCM Requires a Broader Primary-Care Infrastructure

APCM goes beyond simply documenting monthly patient interactions.

CMS requires practices to maintain advanced primary-care capabilities, including:

  • 24/7 access and continuity of care
  • Comprehensive care management
  • Electronic patient-centered comprehensive care planning
  • Care-transition management
  • Coordination with practitioners, home-based services, and community resources
  • Enhanced digital communication options
  • Population-level management
  • Performance measurement and reporting

Practices considering APCM should therefore evaluate their organization-level capabilities, not just individual patient eligibility.

Population-Level Management Is a Major APCM Difference

CMS requires APCM practices to analyze patient-population data and identify gaps in care.

The practice must also be able to risk stratify its population using diagnoses, claims, or other electronic data to identify patients who may require targeted services.

This population-health requirement is a significant operational difference from traditional CCM billing.

APCM Performance Measurement

APCM also includes performance measurement requirements.

CMS identifies pathways such as reporting the Value in Primary Care MIPS Value Pathway or participating in certain qualifying Medicare models or organizations.

This means APCM implementation may involve quality-reporting and organizational requirements beyond the individual patient's medical record.

Both programs require patient consent.

CMS allows written or verbal consent and requires documentation in the patient's medical record.

The patient should be informed that:

  • Only one provider can furnish and be paid for APCM during a calendar month
  • The patient may stop the service at any time
  • Cost sharing may apply

CMS states that APCM consent generally needs to be obtained only once.

CCM similarly permits verbal or written consent when appropriately documented and includes disclosures regarding cost sharing, the one-practitioner monthly limitation, and the patient's ability to stop CCM.

Initiating Visit: APCM vs CCM

The initiating-visit rules differ and should not be assumed to be identical.

CCM

CMS requires an initiating visit before CCM begins for a new patient or a patient who has not been seen by the billing practitioner within the previous year.

APCM

For APCM, CMS states that an initiating visit is required for new patients, but an additional initiating visit is not required when the patient has been seen by the provider or another provider in the same practice within the previous three years or has received APCM, CCM, or PCM from the practice within the previous year.

An Annual Wellness Visit may qualify as the APCM initiating visit when the practitioner responsible for APCM performs the visit.

Care Plan Requirements

Both APCM and CCM use patient-centered comprehensive care planning.

For APCM, CMS requires the practice to develop, implement, revise, and maintain an electronic patient-centered comprehensive care plan.

The plan should be accessible to members of the care team and, as appropriate, individuals outside the billing practice involved in the patient's care. CMS also requires that the patient or caregiver receive a copy.

A comprehensive care plan may address:

  • Chronic-condition problem list
  • Expected outcomes
  • Measurable treatment goals
  • Medication management
  • Functional needs
  • Psychosocial needs
  • Patient preferences
  • Caregiver support
  • Specialist involvement
  • Community resources
  • Care-transition needs

Care Transitions Under APCM

Care-transition management is specifically included in APCM.

CMS requires capabilities for coordination following events such as:

  • Emergency-department visits
  • Hospital discharge
  • Skilled nursing facility discharge
  • Transitions involving other health care settings

CMS also describes timely electronic information exchange and clinically indicated follow-up communication with the patient or caregiver after transitions.

Enhanced Communication Requirements

APCM requires more than telephone availability.

CMS requires practices to offer asynchronous, non-face-to-face communication methods such as:

  • Secure messaging
  • Patient portal communication
  • Email or other permitted electronic communication

The practice must also have capabilities for remote evaluation of prerecorded information, interprofessional electronic or phone consultations, and certain patient-initiated digital communications.

Can Clinical Staff Provide APCM?

Yes. CMS permits auxiliary personnel to furnish APCM services incident to the billing provider's professional services under general supervision when applicable requirements are met.

Auxiliary personnel may include employees, leased employees, or independent contractors who meet applicable Medicare and state requirements.

The billing practitioner remains responsible for the APCM service and for serving as the continuing focal point for the patient's primary care.

CCM Clinical Staff

CCM also allows qualifying clinical-staff services under general supervision for codes such as CPT 99490.

One operational difference is that CCM requires careful tracking of qualifying monthly time for time-based codes, while APCM does not use a minute threshold.

APCM vs CCM Example

CCM Example

A primary care practice manages a patient with diabetes and hypertension. An RN care manager documents 24 minutes of qualifying CCM activity during the month, including medication adherence follow-up, care-plan management, and specialist coordination.

If all Medicare requirements are met, the practice may evaluate CPT 99490.

APCM Example

A primary care practice serves as the continuing focal point for a patient with diabetes, hypertension, COPD, and multiple care-coordination needs. The practice maintains the required primary-care capabilities, comprehensive care plan, enhanced communication, transition management, population-level management, and performance reporting.

Because APCM is not time based, the practice does not need to accumulate a specific monthly minute threshold before evaluating the applicable APCM code.

Does APCM Replace CCM?

No. Medicare continues to maintain both APCM and traditional CCM codes in 2026.

APCM provides an alternative bundled advanced-primary-care structure, while CCM remains available as an individual care-management service when its requirements are met.

The appropriate model depends on the practice's capabilities, patient population, role in the patient's care, and Medicare billing rules.

Can You Bill APCM and CCM Separately for the Same Work?

APCM incorporates elements of CCM and other services into its monthly payment bundle. Practices should not assume that services already represented within the APCM bundle can simply be billed again as separate overlapping care-management services.

Before reporting APCM together with another care-management or communication service, verify the current CMS bundling rules, code-specific instructions, Medicare edits, and payer guidance.

2026 APCM Behavioral Health Add-On Codes

Beginning January 1, 2026, CMS created three optional behavioral-health add-on codes for patients receiving APCM:

CodeServiceG0568Initial psychiatric Collaborative Care Model service with APCMG0569Subsequent psychiatric Collaborative Care Model service with APCMG0570General Behavioral Health Integration with APCM

CMS requires an APCM base code — G0556, G0557, or G0558 — to be reported by the same practitioner in the same month when these optional add-on services are billed.

CMS states that these 2026 APCM behavioral-health add-on codes are not time based.

When CCM May Fit a Practice Workflow

A practice may evaluate traditional CCM when:

  • The patient has two or more qualifying chronic conditions
  • The practice is providing defined chronic-care management activities
  • Qualifying monthly time can be accurately tracked
  • Clinical staff or practitioners are performing CCM work
  • The organization is not operating the broader APCM model for the patient

When APCM May Fit a Practice Workflow

A practice may evaluate APCM when:

  • The practitioner serves as the patient's primary-care focal point
  • The organization has advanced primary-care infrastructure
  • The practice can provide the required care-management capabilities
  • The practice supports enhanced digital communication
  • The organization can perform population-level management
  • The required performance-reporting pathway is available
  • A monthly bundled model better reflects the practice's care-delivery structure

The appropriate approach should be determined from CMS requirements and the actual model of care rather than reimbursement alone.

APCM Implementation Checklist

  • Identify eligible billing practitioners.
  • Confirm the practitioner is responsible for the patient's primary care.
  • Determine whether G0556, G0557, or G0558 applies.
  • Obtain and document patient consent.
  • Complete an initiating visit when required.
  • Provide 24/7 access and continuity capabilities.
  • Maintain a comprehensive electronic care plan.
  • Establish care-transition workflows.
  • Support practitioner, home, and community care coordination.
  • Offer enhanced electronic communication options.
  • Implement population-level analysis.
  • Implement risk stratification.
  • Meet applicable performance-measurement requirements.
  • Review bundled-service billing rules.
  • Review optional 2026 BHI and CoCM add-on codes.
  • Verify current CMS and MAC instructions before billing.

CCM Implementation Checklist

  • Confirm two or more qualifying chronic conditions.
  • Verify expected duration and clinical risk.
  • Complete the initiating visit when required.
  • Obtain and document consent.
  • Create a comprehensive patient-centered care plan.
  • Document qualifying CCM activities.
  • Identify who performed each activity.
  • Track qualifying monthly time.
  • Select the appropriate CCM code family.
  • Avoid duplicate time reporting.
  • Verify current CPT, CMS, MAC, and payer rules.

How ChronicSync Can Help

As Medicare care-management options expand, practices need better visibility into patient eligibility, care plans, care transitions, staff activities, communication, and program enrollment.

ChronicSync helps practices organize longitudinal care workflows, maintain structured patient documentation, track ongoing activities, and improve operational visibility across Chronic Care Management and other care-management programs.

Start your ChronicSync Free Pilot and explore a more organized approach to care management.

Frequently Asked Questions

What is the main difference between APCM and CCM?

CCM primarily uses time-based monthly care-management codes for patients with multiple chronic conditions. APCM is a broader monthly advanced-primary-care bundle that is not based on a specific monthly minute threshold.

What are the APCM codes?

The APCM base HCPCS codes are G0556, G0557, and G0558.

What are the main CCM codes?

The primary CCM CPT codes include 99490, 99439, 99491, 99437, 99487, and 99489.

Is APCM time based?

No. CMS states that APCM does not use the time-based monthly thresholds used by individual care-management codes such as CCM.

How often can APCM be billed?

CMS states that APCM can be billed once per patient per calendar month when the applicable requirements are met.

Yes. CMS allows written or verbal consent, which must be documented in the patient's medical record.

Does APCM require a care plan?

Yes. CMS requires development, implementation, revision, and maintenance of an electronic patient-centered comprehensive care plan.

What is the difference between G0557 and G0558?

Both apply to patients with two or more qualifying chronic conditions, but G0558 additionally requires Qualified Medicare Beneficiary status.

What changed for APCM in 2026?

CMS added optional behavioral-health integration and psychiatric Collaborative Care Model add-on codes G0568, G0569, and G0570 beginning January 1, 2026.

Sources

This article is provided for educational purposes only and does not constitute medical, legal, coding, reimbursement, compliance, or billing advice. CMS, CPT, HCPCS, Medicare Administrative Contractor, and payer rules can change. Verify current requirements before submitting claims.

Reviewed by ChronicSync Team.