| CCM | APCM | |
|---|---|---|
| Program purpose | Time-based care coordination for multi-condition patients | Bundled care-management and communication-technology services in one payment |
| Primary care focus | Any practitioner managing qualifying chronic conditions | Intended for the patient's continuing, comprehensive primary care focal point |
| Patient population | 2+ chronic conditions, 12+ months, significant risk | 3 tiers: 0-1 condition, 2+ conditions, or 2+ conditions + QMB status |
| Payment structure | Per-code payment tied to time thresholds | One flat monthly payment per patient, set by tier |
| Time-based vs bundled | Time-based — minutes must be tracked | Bundled — no minute-counting required |
| Risk stratification | Implicit in the eligibility criteria (condition count, risk) | Explicit tiering by chronic-condition count and QMB status |
| Care plan requirements | Comprehensive electronic care plan required | Comprehensive electronic care plan required |
| Care coordination | Managing care transitions, coordinating with other practitioners | Timely electronic health information exchange with other treating practitioners |
| Communication expectations | Phone and secure messaging encouraged for care continuity | Explicit requirement for asynchronous channels beyond phone (portal, secure messaging, email) |
| Quality/performance requirements | Not a distinct requirement beyond service elements | Not detailed as a separate reporting requirement in the CMS materials reviewed |
| Technology requirements | Certified EHR for structured health information | Certified EHR plus real-time information access and asynchronous communication |
| Documentation | Time must be tracked and documented monthly | No monthly time-tracking; care plan and access/communication infrastructure still documented |
| Operational complexity | Requires monthly time logs per patient | Requires standing up access/communication infrastructure, but no monthly time logs |
| Billing workflow | Select the code matching qualifying time each month | Select the code matching the patient's condition tier |
| Potential overlap | Only one practitioner can bill CCM per patient per month | Only one provider can bill APCM per patient per month; consult current guidance on combining with other care-management codes |
Program Purpose
CCM pays for time-based care coordination for patients with two or more chronic conditions. APCM bundles elements of several existing care-management and communication-technology services — including principal care management, transitional care management, CCM, interprofessional consultations, and e-visits — into one monthly payment reflecting the essential elements of advanced primary care.
Payment Structure: Time-Based vs Bundled
CCM codes are billed based on clinical staff or practitioner time thresholds each calendar month (20 minutes for 99490, additional 20-minute increments for 99439, 60+30 minutes for complex CCM). APCM is billed once per calendar month as a flat, tiered payment and does not require counting or documenting minutes.
Patient Population
CCM requires two or more chronic conditions expected to last at least 12 months, or until death, with significant risk of death, acute exacerbation/decompensation, or functional decline. APCM has three tiers: Level 1 (G0556) for patients with 0 or 1 chronic condition, Level 2 (G0557) for patients with 2 or more chronic conditions, and Level 3 (G0558) for patients with 2 or more chronic conditions who are also Qualified Medicare Beneficiaries.
Care Management Requirements
Both programs require a comprehensive, patient-centered electronic care plan and coordination with other practitioners and care settings. APCM additionally specifies 24/7 patient/caregiver access to a care team member, real-time access to the patient's medical information, the ability to schedule successive routine appointments, and timely follow-up after a hospital, ED, or skilled nursing facility discharge.
Technology Expectations
CCM requires structured recording of patient health information in certified EHR technology. APCM builds on this with an explicit expectation of asynchronous, non-face-to-face communication options beyond phone calls — such as secure messaging, a patient portal, or email — and the ability to remotely evaluate pre-recorded patient information.
Monthly Billing
Only one practitioner can furnish and bill CCM (or APCM) for a given patient during a calendar month. Where CCM's monthly payment amount depends on which time-based code(s) apply, APCM's monthly payment amount depends only on which of the three levels the patient's condition profile places them in.
Suitable Practice Types
Physicians and non-physician practitioners (nurse practitioners, physician assistants, clinical nurse specialists) who serve as the continuing, comprehensive focal point for a patient's primary care — typically general internal medicine, family medicine, geriatric medicine, or pediatrics — can furnish and bill both CCM and APCM services.