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Medicare Care Management & Remote Monitoring

CCM Patient Consent Requirements: Written vs Verbal Consent for 2026

Learn Medicare Chronic Care Management patient consent requirements for 2026, including verbal vs written consent, what patients must be told, documentation requirements, cost sharing, and when new consent is needed.

Updated for 2026. Medicare requires patient consent before Chronic Care Management (CCM) services are provided and billed. The good news for practices is that CMS allows this consent to be obtained verbally or in writing.

The important requirement is not whether the patient signs a particular form. The practice must explain specific information about CCM, obtain the patient's agreement, and document the consent in the medical record.

Yes. CMS requires the patient to provide informed consent before CCM services are billed.

CMS states that the consent may be either written or verbal, but the practice must document it in the patient's medical record.

Consent MethodAllowed by CMS?Documentation Required?Verbal consentYesYesWritten consentYesYes

CMS does not require every Medicare CCM patient to sign a written consent form. Verbal consent can satisfy the Medicare requirement when the required information is explained and the patient's decision is properly documented.

A practice may still choose to use a written consent form for operational consistency, risk management, or documentation purposes. State requirements and other payer policies may also differ.

What Must You Tell the Patient?

CMS identifies several items that should be discussed with the patient before CCM begins.

The patient should be informed about:

  • The availability and nature of Chronic Care Management services
  • Possible patient cost-sharing responsibilities
  • The fact that only one practitioner can provide and bill Medicare CCM services for the patient during a calendar month
  • The patient's right to stop CCM services at any time
  • The fact that stopping CCM generally becomes effective at the end of the calendar month

The medical record should also document that the required information was explained and whether the patient accepted or declined CCM services.

No. CMS states that practices do not need to obtain new CCM consent every month.

Consent is generally obtained once before CCM begins and remains applicable while the patient continues receiving CCM from the same billing practitioner.

No. CMS also states that CCM consent does not need to be renewed annually simply because a new calendar year begins.

A practice may choose to periodically confirm that the patient still wants to participate, but routine annual re-consent is not a Medicare CCM requirement.

CMS states that new consent must be obtained when the patient changes to a different practitioner who will bill for the CCM service.

This is important because Medicare generally permits only one practitioner to bill CCM for a patient during a calendar month.

Example

A Medicare patient originally receives CCM from Practice A. Several months later, the patient changes primary care providers and Practice B becomes responsible for CCM.

Practice B should obtain and document the patient's consent before furnishing and billing its CCM services.

The following example can help practices structure a CCM consent conversation. It should be adapted to the organization's workflow, patient population, and applicable requirements.

Medicare offers Chronic Care Management services for patients with multiple chronic conditions. Through this service, our care team can help coordinate your care between visits, manage your care plan, help with medications and appointments, and communicate with other healthcare professionals involved in your care.
Medicare cost sharing may apply. Only one healthcare practitioner can provide and bill Medicare for Chronic Care Management services for you during a calendar month.
You may stop Chronic Care Management services at any time. Do you understand these services and agree to participate?

If the patient agrees, the practice should document the consent and relevant discussion in the medical record.

A medical-record entry could document:

Example: Patient was informed about Chronic Care Management services, including the nature of the service, potential Medicare cost sharing, that only one practitioner may provide and bill CCM during a calendar month, and the patient's right to discontinue CCM services. Patient verbalized understanding and provided verbal consent to participate.

The exact documentation format may vary based on the EHR and practice workflow.

What If the Patient Declines CCM?

If the patient does not want to participate, the practice should respect the decision and document that CCM was explained and declined.

CMS specifically recommends documenting whether the patient accepted or declined the service after the required information was explained.

Can a Patient Cancel CCM?

Yes. Patients have the right to stop CCM services.

CMS guidance states that patients should be informed of this right when consent is obtained. For Medicare CCM, discontinuation generally becomes effective at the end of the calendar month.

CMS explains that obtaining consent helps make sure patients understand their participation, possible cost-sharing responsibilities, and the limitation that only one practitioner can bill CCM during a calendar month.

Consent also helps prevent situations where multiple practices attempt to bill CCM for the same beneficiary without the patient's understanding.

Should You Discuss Medicare Cost Sharing?

Yes. Possible cost sharing is specifically included in CMS's CCM consent requirements.

Patients should understand that Medicare CCM is generally not automatically free simply because it is delivered outside a traditional office visit. Deductible or coinsurance obligations may apply depending on the patient's coverage.

Practices should avoid promising a specific out-of-pocket amount unless the patient's benefits have been verified.

Can a Secondary Insurance Cover CCM Cost Sharing?

Some patients may have supplemental or secondary coverage that pays some or all of their Medicare cost-sharing responsibility. Coverage varies by plan.

Practices should verify benefits rather than guaranteeing that a secondary insurer will cover the patient's portion.

Only one practitioner may provide and bill Medicare CCM for the patient during a calendar month.

Eligible billing practitioners can include physicians and certain qualified non-physician practitioners when all Medicare requirements are satisfied.

This makes it important for practices to determine whether another provider is already managing and billing CCM before enrollment.

Obtaining consent does not by itself make a patient or service eligible for CCM billing.

Practices also need to evaluate requirements such as:

  • The patient having two or more qualifying chronic conditions
  • The expected duration and clinical risk associated with those conditions
  • An initiating visit when required
  • A patient-centered comprehensive care plan
  • 24/7 access and continuity-of-care requirements
  • Care coordination
  • Qualifying monthly service time for time-based CCM codes
  • Appropriate supervision
  • Accurate documentation
  • Confirm the patient is potentially eligible for CCM.
  • Explain what Chronic Care Management is.
  • Explain how the service may help coordinate ongoing care.
  • Explain possible cost-sharing responsibilities.
  • Tell the patient that only one practitioner can bill CCM during a calendar month.
  • Explain that the patient can stop CCM services.
  • Ask whether the patient agrees to participate.
  • Document whether consent was verbal or written.
  • Document that the required information was explained.
  • Document whether the patient accepted or declined.
  • Store written consent when your practice uses a signed form.
  • Obtain new consent if the patient changes to a new CCM billing practitioner.

CMS requires consent before CCM services are billed. Build the consent step into the enrollment workflow rather than trying to reconstruct it later.

2. Recording Only 'Patient Agreed'

Documentation should support that the required CCM information was explained, including possible cost sharing, the one-practitioner billing limitation, and the patient's right to stop services.

CMS permits either verbal or written CCM consent. A practice may choose written consent, but Medicare does not universally require a signed CCM form.

4. Forgetting About Cost Sharing

Possible cost sharing is part of the information CMS expects practices to discuss with patients.

CMS does not require monthly CCM re-consent. Requiring unnecessary repeated consent can create extra administrative work.

When a new practitioner becomes responsible for furnishing and billing CCM, CMS requires that practitioner to obtain and document new consent before providing the service.

How ChronicSync Can Help

CCM enrollment becomes harder to manage when patient consent, care plans, monthly activities, time tracking, and follow-up are spread across different spreadsheets or disconnected systems.

ChronicSync helps practices organize chronic-care workflows and maintain clearer visibility into patient enrollment and ongoing care-management activities.

A structured enrollment workflow can help teams identify whether consent has been collected before patients move into active CCM management.

Start your ChronicSync Free Pilot and explore a more organized approach to Chronic Care Management.

Frequently Asked Questions

No. CMS allows either written or verbal informed consent as long as the required information is explained and the consent is documented in the patient's medical record.

Yes. CMS explicitly permits verbal CCM consent.

No. CMS states that consent does not need to be obtained monthly.

No. CMS does not require annual re-consent solely because a new year begins.

CMS requires new consent when the patient changes to a different practitioner who will furnish and bill CCM services.

Patients should be informed about the availability of CCM, possible cost sharing, the limitation that only one practitioner may provide and bill CCM during a calendar month, and their right to stop the service.

Should declined CCM services be documented?

Yes. CMS recommends documenting that the required information was explained and whether the patient accepted or declined CCM.

Sources

This article is provided for educational purposes only and does not constitute medical, legal, reimbursement, or billing advice. Medicare, state, and commercial-payer requirements can change. Verify current CMS, Medicare Administrative Contractor, state-law, and payer requirements before implementing or billing CCM services.

Reviewed by ChronicSync Team.