Three Medicare care management programs now overlap in the same patient population, and for any given patient in any given month, a practice bills one of them. Chronic Care Management (CCM) has been separately payable since 2015. Principal Care Management (PCM) followed for patients whose care revolves around a single complex condition. Advanced Primary Care Management (APCM) arrived on January 1, 2025 as a monthly bundle with no minute counting. Choosing between them comes down to three questions: who owns this patient’s primary care, how many conditions drive the care plan, and whether your team wants to track time. This comparison covers eligibility, documentation, staffing, and concurrent billing rules so clinical and billing staff can decide together.
The Short Version
| APCMYou own the patient’s primary care and want out of minute tracking | CCMTwo or more chronic conditions, comprehensive care plan, time documented | PCMOne complex condition driving the care plan, often a specialist |
What Each Program Pays For
Advanced Primary Care Management
APCM pays a single monthly amount for making a defined set of primary care capabilities available, rather than for minutes logged. CMS built it as a bundle that already contains elements of CCM, PCM, transitional care management, virtual check-ins, remote evaluation of pre-recorded patient information, and interprofessional consultations.
Three HCPCS codes sort patients by complexity. G0556 covers patients with one or no chronic conditions. G0557 covers patients with two or more chronic conditions expected to last at least 12 months or until death, and placing the patient at significant risk of death, acute exacerbation or decompensation, or functional decline. G0558 covers patients meeting the G0557 criteria who are also Qualified Medicare Beneficiaries.
The requirements are capability-based. A practice must obtain and document consent, conduct an initiating visit for new patients where required, provide 24/7 access and continuity of care, deliver comprehensive care management, maintain an electronic patient-centered comprehensive care plan, coordinate care transitions, offer enhanced communication methods, conduct population-level management, and report performance through the Value in Primary Care MIPS Value Pathway or participation in a qualifying model. CMS notes these elements apply when clinically appropriate, so not every element is furnished every month.
Chronic Care Management
CCM is time-based and requires multiple chronic conditions, specifically two or more expected to last at least 12 months or until death and placing the patient at significant risk. The CPT codes split by who performs the work and how complex the case is. CPT 99490 covers the first 20 minutes of clinical staff time per calendar month, with 99439 as the add-on for each additional 20 minutes. CPT 99491 and 99437 cover time performed personally by the physician or other qualified health care professional. Complex CCM, CPT 99487 with add-on 99489, applies to patients requiring moderate or high complexity medical decision making and carries a longer base time requirement.
CCM is not limited to primary care. Any eligible billing practitioner may furnish it, though only one practitioner may bill it for a patient in a calendar month, and the consent must make that clear.
Principal Care Management
PCM covers care management organized around one complex chronic condition expected to last at least three months, where the condition requires a disease-specific care plan and either frequent medication adjustments or management made complex by comorbidities. CPT 99424 covers the first 30 minutes furnished personally by the physician or other qualified health care professional, with 99425 as the add-on. CPT 99426 and 99427 cover the equivalent clinical staff time.
PCM is often the better fit for a specialist who is managing the condition that dominates the patient’s care without taking responsibility for all of that patient’s primary care.
How APCM, CCM, and PCM Compare
| Element | APCM | CCM | PCM |
|---|---|---|---|
| Codes | G0556, G0557, G0558 | 99490, 99439, 99491, 99437, 99487, 99489 | 99424, 99425, 99426, 99427 |
| Condition requirement | None for Level 1; two or more for Levels 2 and 3 | Two or more chronic conditions | One complex chronic condition |
| Expected duration | At least 12 months or until death | At least 12 months or until death | At least three months |
| Monthly time threshold | None | 20 minutes for the base code, more for complex CCM | 30 minutes for the base code |
| Who bills | The practitioner responsible for all of the patient’s primary care | Any eligible billing practitioner, one per patient per month | Often a specialist managing the dominant condition |
| Care plan | Electronic, patient-centered, comprehensive | Comprehensive | Disease-specific |
| Billing frequency | Once per patient per calendar month | Base code once per month, add-ons by time | Base code once per month, add-ons by time |
Payment amounts differ meaningfully across the three programs and across APCM levels, and they are updated annually and adjusted by locality. Verify current amounts for your Medicare Part B locality in the CMS Physician Fee Schedule Look-up Tool rather than relying on national averages quoted in secondary sources.
Which Program Fits Which Patient
Work through the questions below, or read the summary that follows if you would rather scan.
Decision Tool: Start Here
Yes, our practice is responsible for all of this patient’s primary care
Next question: does your team want to keep tracking monthly minutes?
No, we want out of minute tracking
Bill APCM. Choose G0556 for a patient with one or no chronic conditions, G0557 for two or more, and G0558 when a G0557 patient is also a Qualified Medicare Beneficiary. Do not separately bill CCM, PCM, or TCM for that patient that month.
Yes, our documentation of time is already reliable
Model both before choosing. For a patient with two or more chronic conditions receiving substantial monthly coordination, CCM with add-on codes may capture more than APCM Level 2. For a patient with one chronic condition, APCM Level 1 is available where CCM is not.
No, another practice owns this patient’s primary care
Next question: how many conditions drive the care plan you are managing?
One complex condition dominates the care
PCM is the fit. Use 99424 and 99425 for practitioner time, 99426 and 99427 for clinical staff time. The disease-specific care plan is the documentation anchor, and the condition must be expected to last at least three months.
Two or more chronic conditions drive the care plan
CCM applies. Any eligible billing practitioner may furnish it, not only primary care, but only one practitioner bills it per patient per month. Confirm no one else is already billing CCM, PCM, or APCM for that patient.
In summary:
- Your practice is the patient’s primary care home and you want to stop counting minutes. Bill APCM, choosing the level by complexity. Do not also bill CCM, PCM, or TCM for that patient that month.
- The patient has two or more chronic conditions and your team already documents care coordination time reliably. CCM may pay more than APCM Level 2 for patients receiving substantial monthly time, particularly when add-on codes apply.
- One condition drives nearly all of the care and your practice is not managing the rest. PCM is the fit, and the disease-specific care plan is the documentation anchor.
- The patient has a single chronic condition and your practice is their primary care home. APCM Level 1 is available where CCM is not, since CCM requires two conditions.
Worth Testing Before You Switch
APCM removes time tracking, which lowers administrative burden, but a patient receiving heavy monthly coordination may be documented more completely under CCM with add-on codes. Run both models against a sample of your enrolled panel before converting an entire program.
What You Cannot Bill Together in the Same Month
The overlap rules are where most denials originate. APCM is a bundle, so in a month a practice bills G0556, G0557, or G0558, that same practitioner does not separately bill the services folded into it, including CCM, PCM, TCM, interprofessional consultations, and the communication technology-based services. CCM and PCM are not billed by the same practitioner for the same patient in the same month. Non-complex and complex CCM are not billed together, and the clinical staff and practitioner CCM tracks are not billed together.
One practical consequence: if a specialist is billing PCM for a patient’s dominant condition and the primary care practice wants to move that patient to APCM, the two practices need to coordinate. Only one care team can be paid for the overlapping month.
How Each Program Works Alongside Remote Patient Monitoring
Remote Patient Monitoring (RPM) is a separate service family from care management, and practices commonly run it alongside a care management program for the same patient. The constraint is that time counted toward RPM treatment management is not also counted toward a time-based care management code. Because APCM carries no time threshold, that double-counting question does not arise on the APCM side, which is part of why some practices pair APCM with RPM.
Note also that the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) proposes significant changes to RPM staffing and billing. Those proposals are directed at remote monitoring, not at the care management programs compared here, but a practice running both should track the final rule before setting 2027 staffing plans.
What Changed for 2026
- APCM gained optional behavioral health add-on codes. HCPCS G0568, G0569, and G0570 support billing for Behavioral Health Integration and the Psychiatric Collaborative Care Model alongside APCM, paid at the national non-facility rate.
- RHC and FQHC care coordination billing moved further toward fee-for-service. CMS pays the national non-facility rate for services designated as care management services when billed by RHCs and FQHCs. G0511 had already been unbundled, and G0512 and G0071 are no longer reportable as of January 1, 2026.
- Payment amounts were updated. Care management rates change with the annual fee schedule, so a rate card built in 2025 needs rechecking against the current PFS files.
How DrKumo Supports Care Management Programs
DrKumo provides secure, HIPAA-compliant digital health technology that supports the workflows underneath these programs: structured documentation, care plan maintenance, and the between-visit patient contact that care management depends on. The platform supports remote patient monitoring alongside chronic care management, giving care teams both physiologic data from medical devices as defined by the FDA and the structured records that CMS documentation requirements call for. Practices building a program can review DrKumo’s comprehensive guide to RPM.
DrKumo also supports provider-led Disease Management Protocols for the conditions that most often qualify patients for these programs, including hypertension, diabetes, heart failure, and COPD. For FQHCs and RHCs and community providers adapting to the shift toward individual code billing, having consistent documentation in place before the program scales is what determines whether it holds up under review. DrKumo is a technology provider and is not a clinical entity. Providers retain full clinical responsibility for patient care decisions and for selecting the appropriate billing code.
Key Takeaways
APCM, CCM, and PCM solve different problems. APCM pays a monthly bundle with no time threshold to the practitioner responsible for a patient’s primary care. CCM pays for documented time managing two or more chronic conditions and is open to any eligible billing practitioner. PCM pays for documented time managing one complex condition under a disease-specific care plan.
Only one of the three is billed for a patient in a calendar month, and APCM absorbs the others for the practitioner billing it. Before converting an existing CCM panel to APCM, model both against your actual documented time, because patients receiving heavy monthly coordination may be captured more completely under CCM with add-on codes.
Verify current payment amounts in the CMS PFS Look-up Tool for your locality, confirm consent and initiating visit documentation before enrollment, and track the CY 2027 final rule if your practice also runs RPM.
Data-Driven Care Starts Here
Build the documentation foundation your care management program depends on.
To learn how DrKumo can help your organization deliver secure, HIPAA-compliant remote patient monitoring and care management technology, contact us today. Our team is ready to support your journey toward better patient care.
Frequently Asked Questions
Can a practice bill APCM and CCM for the same patient in the same month
No. APCM is a bundle that already includes CCM, PCM, TCM, and several communication technology-based services. The practitioner billing APCM does not separately bill those services for that patient that month.
What is the main difference between CCM and PCM
Condition count and care plan scope. CCM requires two or more chronic conditions expected to last at least 12 months and a comprehensive care plan. PCM covers one complex condition expected to last at least three months under a disease-specific care plan, and base time is 30 minutes rather than 20.
Who is eligible to bill APCM
A physician or non-physician practitioner who is responsible for all of the patient’s primary care and serves as the focal point for their health care services, with documented consent. CMS describes the codes as primarily for primary care specialties such as internal medicine, family medicine, geriatrics, and pediatrics.
Does APCM require an initiating visit
For new patients, yes, and it is paid separately. It is not required if the practice has seen the patient within the past three years or furnished APCM, CCM, or PCM to that patient within the past year. A Medicare Annual Wellness Visit may serve as the initiating visit when performed by the practitioner who will provide APCM.
Can contracted staff furnish APCM services
CMS states that auxiliary personnel may furnish APCM services incident to the billing provider’s professional services under general supervision, and that auxiliary personnel may be employees, leased employees, or independent contractors who meet applicable licensure and program requirements. This differs from the staffing restriction CMS has proposed for RPM in CY 2027.
References
Centers for Medicare and Medicaid Services. (2026). Advanced Primary Care Management Services. CMS.gov.
Centers for Medicare and Medicaid Services. (2025). Advanced Primary Care Management (APCM) Services FAQ. CMS.gov.
Centers for Medicare and Medicaid Services. Chronic Care Management Services (MLN booklet). CMS.gov.
Centers for Medicare and Medicaid Services. Care Management. CMS.gov.
Centers for Medicare and Medicaid Services. (2025). Calendar Year 2026 Medicare Physician Fee Schedule Final Rule (CMS-1832-F). CMS.gov.
Centers for Medicare and Medicaid Services. (2026). FQHC and RHC News and Announcements. CMS.gov.
Centers for Medicare and Medicaid Services. Physician Fee Schedule Look-up Tool Overview. CMS.gov.
Disclaimer: This article is intended for informational purposes only and does not constitute medical advice, legal advice, billing advice, or financial guidance. Medicare coding, coverage, and payment requirements are subject to change; always consult official CMS sources and your Medicare Administrative Contractor for current requirements. DrKumo is a technology provider and is not a clinical entity. Always consult with a licensed healthcare provider for guidance on diagnosis, treatment, or medical decisions. References to the Centers for Medicare and Medicaid Services do not constitute or imply an endorsement by CMS or the U.S. Government.
