The Advanced Primary Care Management (APCM) codes introduced in the 2025 Physician Fee Schedule Proposed Rule offer a value-based care approach to managing primary care and chronic care patients. This streamlined alternative replaces time-based Chronic Care Management (CCM), Principal Care Management (PCM), and Transition Care Management (TCM) codes with a set of bundled codes.
What are the Advanced Primary Care Management (APCM) codes?
The APCM codes provide a flat fee per primary care patient per month with no need to track time. Practices could dramatically reduce the administrative billing burden and likely increase profitability depending on their patient population. The proposed codes and rates include:
- GPCM1: Any primary care patient is eligible for a proposed reimbursement of $10 per patient per month
- GPMC2: Similar to CCM code requirements, patients must have 2 or more chronic conditions to be eligible for a proposed reimbursement of $50 per patient per month/patient
- GPCM3: Similar chronic care requirements to GPMC2 but with a higher proposed reimbursement for Qualified Medicare Beneficiary (QMB) at $110 per patient per month; this compensates practices for the increased resources required to care for these patients, who are under the federal poverty level and often have social determinants of health issues and limited access to care
While the proposed reimbursement rates are generally lower than CCM or similar services each month, it potentially provides reimbursement for a larger number of patients since there are no time-based requirements to meet.
What are the Advanced Primary Care Management (APCM) requirements?
While the APCM codes do not require time tracking per patient, they do require 13 service elements to be available to all patients. Many of these elements are already required for providing CCM and are likely relatively easy for most practices to provide.
- Patient Consent: Patients must consent to the service and consent must be documented in their medical record.
- Initiating Visit: New patients or those who have not had a visit in three years must have an initiating appointment for APCM.
- 24/7 Access: Patients must have 24/7 access to urgent care access with a care team/practitioner.
- Continuity of Care: A designated team member must provide continuity of care for routine appointments.
- Alternative Care Delivery: Home visits, extended hours, telehealth, and/or non-traditional office visits must be available.
- Comprehensive Care Management: Systematic needs assessment, preventative services, medication reconciliation, and oversight of self-management are available.
- Electronic Care Plan: A comprehensive electronic care plan is documented, managed, and accessible to the patient and provider.
- Care Transitions Coordination: The provider can facilitate transitions between healthcare settings and providers with timely follow-up communication.
- Ongoing Communication: Practice coordinates across various service providers to communicate and document the patient’s needs and preferences.
- Enhanced Communication Methods: Communication is available through digital means, such as secure messaging, email, and patient portals.
- Population Data Analysis: Analysis can be conducted to identify care gaps and provide care interventions.
- Risk Stratification: Data can be used to identify and proactively offer services to high-risk patients.
- Performance Measurement: Providers can assess the quality and total cost of care and demonstrate the use of Certified EHR Technology.
Who should adopt Advanced Primary Care Management (APCM) codes if approved?
While APCM codes cannot be billed concurrently with CCM or PCM codes, they can be billed in conjunction with RPM and RTM codes. Currently, for patients dual-enrolled in CCM and RPM time spent on many patient activities must be attributed to either CCM or RPM time but cannot be double-counted.
In reality, most practices attribute time that qualifies for either to CCM since it has higher reimbursement. That means fewer patients are meeting the threshold for billing RPM CPT® Codes 99457 and 99458 since only time from certain activities like reminding patients to take readings and analyzing readings are attributed to RPM.
With APCM, practices can bill APCM and then apply all time that would have fallen under the CCM or RPM time codes to RPM. This allows practices to collect APCM revenue on all primary care patients and maximize RPM reimbursements for chronic care patients. It also dramatically simplifies time accounting and billing. This could help practices increase revenue while improving the quality of care, particularly in managing patients with chronic conditions.
Increasing RPM enrollment and revenue
With the simplicity of APCM codes, practices can look to provide proactive, continuous care to more patients without concern for overlapping time between CCM and RPM. For practices with limited staff, a managed RPM solution can improve outcomes and increase total practice revenue without impacting CCM programs or overburdening staff. Remote monitoring staff that acts as an extension of a practice’s team can provide cost-effective RPM care without needing to track any overlapping time with CCM care.
Value-based care is here to stay and the APCM codes are one step in that direction. Once approved, practices can take the dependable reimbursement of APCM with minimal administrative support and still bill for time associated with RPM.
Want to learn more about the APCM codes can impact your practice reimbursement
Optimize Health can help you analyze the potential reimbursement increase from adopting an APCM + RPM approach to your chronic care patients. Set up a free consultation with one of our RPM experts to learn more.