CMS’s Advanced Primary Care Management (APCM) program gives practices a new way to deliver coordinated, relationship-driven care while strengthening reimbursement. CoachCare helps practices operationalize APCM through integrated technology, patient engagement tools, and clinical support designed to extend care beyond the office visit. With more than 1,000 implementations and 500,000+ patients served, CoachCare helps practices launch and scale APCM with confidence.
CoachCare brings deep expertise in CMS program implementation, having helped practices nationwide succeed with chronic care management, remote patient monitoring, principal care management and other programs. Our comprehensive understanding of CMS requirements, combined with our proven platform technology, positions us uniquely to support your APCM implementation.
We offer practices a complete suite of services to ensure APCM success:
From initial implementation to providing ongoing clinical care services to support APCM and your practice, CoachCare serves as your ongoing partner in APCM success. We continuously monitor regulatory changes, update best practices, and provide optimization recommendations to ensure your practice maximizes both patient outcomes and financial returns.
Let CoachCare help determine if APCM is right for your practice and create a customized implementation plan. Contact our team today to schedule a personalized consultation and learn how we can support your transition to advanced primary care management.
Advanced Primary Care Management (APCM) is an innovative program established by the Centers for Medicare & Medicaid Services (CMS) in 2025. APCM was launched to address longstanding challenges in primary care delivery, including fragmented care, inadequate compensation for comprehensive services, and the need to better support practices in managing complex patient populations and social determinants of health.
At its core, APCM strengthens the infrastructure behind primary care—giving practices the tools, workflows, and reimbursement framework to better support patients between visits, improve continuity, and manage population health at scale.
With APCM, practices can:
CoachCare helps practices bring these capabilities into everyday care delivery through integrated technology, patient engagement tools, and clinical support designed to extend care beyond the office visit.
Advanced Primary Care Management aims to strengthen primary care by recognizing and supporting comprehensive, longitudinal care management. Unlike traditional fee-for-service models, APCM bundles various care management services into a single monthly payment. This approach allows practices to focus on delivering high-quality, patient-centered care without the burden of tracking multiple billing codes.
Key objectives of APCM include:
Unlike traditional care management programs, APCM is not time-based, giving practices greater flexibility to deliver care in the ways that best support their patient population.
CMS established three APCM HCPCS codes to support varying levels of patient complexity. Together, these codes create a monthly reimbursement pathway for delivering longitudinal, relationship-based primary care services across the Medicare population.
These tiered payments recognize that patients with multiple chronic conditions or social risk factors require more intensive care management.
*National average Medicare reimbursement shown. Actual payment varies by geography and payer.
Advanced Primary Care Management (APCM) includes 13 core service elements that build upon existing Chronic Care Management (CCM) and Principal Care Management (PCM) services, recognizing care management as a core component of advanced primary care delivery. While APCM shares many elements with these programs, it removes time-tracking requirements, allowing practices greater flexibility in how care is delivered while maintaining a focus on comprehensive, longitudinal patient support.
APCM emphasizes the capabilities needed to deliver advanced primary care while allowing practices to tailor services to individual patient needs.
To bill for APCM services, practices must demonstrate capabilities in all these areas. However, CMS proposes flexibility in how these services are delivered, recognizing that care needs and the services provided will vary month to month.
CoachCare’s remote care management platform is well-positioned to support APCM implementation, aligning closely with the program’s key elements. Our solutions support timely access to care team support, comprehensive care management, and population health analytics aligned to APCM requirements. Our patient engagement tools facilitate enhanced communication, while our analytics capabilities support performance measurement and quality improvement. This alignment allows practices to seamlessly transition to the APCM model, leveraging our existing remote care management infrastructure to meet new program requirements and improve patient outcomes.
APCM services can be billed by physicians and qualified healthcare professionals who serve as the focal point for all needed health care services and are responsible for a patient’s primary care. This includes:
Medicare beneficiaries are eligible for APCM services. The level of service (G0556, G0557, or G0558) depends on the patient’s number of chronic conditions and Qualified Medicare Beneficiary status.
Attribution Process
Patient attribution in APCM is intended to be based on patient choice and documented consent. Specifically:
CoachCare’s care management platform includes robust features for documenting and managing patient consent and attribution, allowing for easy tracking of patient assignments to specific providers, ensuring compliance with APCM’s single-provider billing requirement. Additionally, our platform’s annual review capabilities align well with the expected yearly attribution update process.
To participate in APCM, practices must have certain technological capabilities:
As the industry moves towards APCM implementation, practices and health systems will need to assess their current capabilities and identify areas for improvement. Technology solutions can play a crucial role in helping practices meet APCM requirements and deliver high-quality, comprehensive primary care under this new model.
CoachCare’s comprehensive platform has been designed and stands ready to meet these technology requirements.
APCM performance measurement focuses on quality of care, patient outcomes, total cost of care, and the use of Certified EHR Technology. For many organizations, APCM reporting may align with existing participation in Medicare Shared Savings Program ACOs, ACO REACH, Making Care Primary, MIPS, and other CMS quality initiatives.
For MIPS-eligible clinicians, APCM aligns closely with the Value in Primary Care Merit-based Incentive Payment System (MIPS) Value Pathway (MVP), which emphasizes quality measures tied to preventive care, chronic disease management, care coordination, behavioral health, patient-centered care, and screening for social drivers of health.
Performance measurement activities may include:
Practices evaluating APCM should review current quality reporting workflows and assess how APCM requirements align with existing reporting programs and internal operational capabilities.
CoachCare supports APCM performance measurement through integrated reporting, data access, population health analytics, and actionable care insights that help practices identify care gaps, monitor outcomes, and support continuous quality improvement at scale.
CoachCare helps practices navigate these requirements through integrated technology, operational support, and care management workflows designed to make APCM implementation more scalable and sustainable.
Key considerations include:
Because APCM intersects with multiple Medicare reimbursement pathways, practices should review program eligibility, billing requirements, and operational workflows to determine the best implementation approach for their organization.
CoachCare supports practices through that evaluation—helping teams align clinical workflows, care management services, and reimbursement strategy under APCM.
For the most up-to-date and authoritative information on APCM, refer to these official CMS resources:
CMS Advanced Primary Care Management Services – CMS Overview of APCM services, billing requirements, service elements, and eligibility
CMS Care Management Resources — CMS care management resource hub, including APCM guidance and related program resources.
Medicare Coverage of Advanced Primary Care Management Services Fact Sheet — patient-facing APCM overview, coverage details, and Medicare benefit information.
CY 2026 Medicare Physician Fee Schedule Final Rule Fact Sheet — latest CMS updates related to APCM policy and reimbursement changes for 2026.
Additional APCM implementation guidance, reimbursement updates, and policy analysis:
These resources offer additional perspectives on APCM implementation, quality reporting, reimbursement strategy, and operational planning for practices adopting advanced primary care delivery models.
APCM stands for Advanced Primary Care Management, a Medicare-funded initiative that supports primary care providers (PCPs) in delivering ongoing, patient-centered care. This proactive approach goes beyond occasional check-ins, aiming to keep patients engaged with their healthcare providers, ensure adherence to treatment plans, and address health issues early on.
Q&A from Understanding APCM: Requirements, Technology & Implementation webinar.
This Q&A resource compiles the key questions and answers from the webinar, Understanding APCM: Requirements, Technology & Implementation. It covers essential topics like compliance, technology integration, and practical steps for implementing Advanced Primary Care Management. Designed to address your most pressing questions, this guide serves as a practical tool for navigating the APCM model and optimizing care delivery.
In case you missed it, the webinar is available on-demand here.
A: Medicare beneficiaries are eligible for APCM services. The level of service (G0556, G0557, or G0558) depends on:
• Level 1 (G0556): Patients with one or fewer chronic conditions
• Level 2 (G0557 Patients with two or more chronic conditions
• Level 3 (G0558): Qualified Medicare Beneficiary patients with two or more chronic conditions
A: These codes are not affected by telehealth codes or visits. They will be billed the same as current CCM and RPM codes with the location being in the office.
A: Yes, absolutely. APCM services can be provided alongside ACO participation and RPM services. Like how CCM works with RPM, these programs complement each other, particularly in driving patient accountability and satisfaction.
A: CoachCare will be ready to support APCM services starting January 1, 2025. We recommend practices begin preparation now by:
1. Completing our APCM readiness assessment
2. Evaluating patient populations for APCM eligibility
3. Planning workflow adjustments
For practices not ready to implement APCM in January, you can also start with traditional CCM and transition when ready. To facilitate future transitions, our consent process covers both CCM and APCM programs for all new enrollments.
A: Not that we are aware of. CCM and RPM services can currently be provided if someone is being seen at a SNF so all guidance points to this program being billed the same way.
Providers will need thorough documentation including verbal patient consent,
eligibility verification (confirmation of chronic conditions and primary care attribution), and service detail (care coordination efforts, patient communication, and interventions).
Payment for APCM codes will not be performance-based but tied to providing required care management services. Over time, performance measurement (e.g., quality outcomes, patient engagement) may influence payment adjustments.
Our data analytics approach leverages multiple data sources, including your existing EHR system (including Epic), practice analytics platforms, claims data when available, and real-time patient monitoring data. Using these sources, we perform comprehensive patient data analysis to stratify patients into APCM tiers, identify care gaps and needs, and assign appropriate interventions and goals. For practices without existing analytics capabilities, we offer access to ReportingMD’s population health platform through our partnership to ensure robust data analysis capabilities.
Yes, APCM follows a single-provider attribution model similar to other Medicare care management programs. Only one provider (identified by their NPI number) can bill APCM services per patient per month, and this requires documented patient consent.
There are major changes in billing structure for FQHCs and RHCs next year as well, detailed in this article. Starting in 2025, FQHCs will transition from the general G0511 to specific service-based codes for programs such as CCM, PCM, PCM, RTM, APCM and others. FQHCs will have the same billing rules are non-FQHCs, but will have a 6-month grace period to make adjustments to their workflows, billing systems, staff training, etc.
If you are interested in learning more about what this means for FQHCs specifically, be sure to complete a readiness assessment form and we will schedule some 1:1 time with you to discuss.
The goal is to have APCM payment models be more aligned with groups that are working with an ACO or alternative payment models. If you are participating with one of these full risk programs, it is more likely that your “spend” will be more aligned with patients who need access to care rather than minutes spent.
We would welcome the opportunity to provide a side-by-side analysis of both options. APCM is not the right fit for everyone, and traditional CCM/RPM may be the right choice for now.
As these are new codes, we have not finalized our pricing for our clients. The pricing will be based on structure and care delivery for each tier of patient attribution. For groups that need access to population health tools, we will include the cost of those tools in our pricing
Yes, RPM requirements have remained the same year over year and can (and in many cases, should) be paired with APCM. These services are not considered duplicative.
There has been no guidance on any changes to MVP reporting at this time. Normal deductibles and copays still apply.
The essence of these codes is that there are no outreach requirements, these are not time-based codes, but the intent is to allow for the right care for the right patient, at the right time. More meaningful interventions for patients as needed is the overall goal. This is how we’ve always defined care management and are excited for these new payment models.
APCM codes are not replacing existing CCM codes – both code sets will continue to exist. However, for a given patient. Providers will need to choose if they would like enter the APCM model and then report that election to Medicare.
Providers need to demonstrate that they have all service elements available for their patients. Then document consent, care plans, service logs, and ongoing reviews. Care plans should include details of chronic disease management, preventative care, patient engagement activities, etc., and service logs should track services provided, including communication and coordination efforts. Our care management services provide all the care coordination and patient management and outreach. We work in coordination with your practice staff to provide a seamless care experience for your patients and document the care for billing.
Our software creates patient care plans based on medical condition, provider direction, and patient center goals. Care plans are built from our robust set of evidence based clinical goal templates and protocols built in. These protocols are adapted for each practice.. Our clinical teams create and manage to the care plan, using assessments, goal tracking and tasking to coordinate care.
No, APCM can be billed by any qualified healthcare professional who serves as the focal point for all needed health care services and is responsible for a patient’s primary care. This includes primary care physicians, family medicine practitioners, internal medicine physicians, geriatricians, and qualified advanced practice providers (NPs, PAs).
APCM has a single-provider billing requirement, it will be based on the providers’ NPI and will be provider-choice to bill for APCM or CCM.
As these are Medicare HCPCS codes, they are specifically designed for Medicare billing. However, commercial payers may choose to recognize and reimburse for these codes – similar to how many commercial plans currently cover CCM services. Final payment rates will be published when CMS releases the final fee schedule conversion factor in January 2025. 2025 Fee schedule has not been finalized yet. Pay rates were indicated within the CMS final rule published November 1st. The three new HCPCS codes for APCM are primarily designed for Medicare billing and are not mandated for use by commercial payers. Commercial payers may choose to adopt these codes, but it’s not guaranteed.
Medicare Advantage plans have to follow the Medicare fee-for-service codes, unless they are providing those services themselves. But, just like traditional CCM, if the MA plan can prove to Medicare that they are providing these services, there could be a carve out or denial for coverage.
Mental health assessments are an integral part of APCM services and can be performed as needed without specific time requirements. Unlike current care management codes, APCM eliminates the need to track time spent on these assessments, focusing instead on completing necessary evaluations and implementing appropriate follow-up care. These assessments do not affect the ability to separately bill for Behavioral Health Integration (BHI) services when appropriate, allowing practices to provide comprehensive mental health care as part of their regular care management activities.
These codes do not need to be paired with any office visit codes; they do not need a modifier and are billed separately. Based on what we’ve read in the final rule so far, these codes will be billed monthly at the beginning of the month vs. the end of the month like CCM. Our integration will create claims directly in the EHR and provide necessary compliance documentation for each claim.
Practices who are participating in MIPS will already be meeting the analytics requirements for these codes. The value pathways and gaps in care can be utilized to direct care for patients, and support MIPS goals and rewards.
Starting with Chronic Care Management (CCM) now and transitioning to Advanced Primary Care Management (APCM) when it becomes available in 2025 can be a sound strategy. APCM builds on and incorporates elements of existing care management programs, including CCM, so the experience your practice gains with CCM workflows and documentation will help prepare you for APCM implementation. APCM eliminates many administrative burdens that exist with CCM, such as time-tracking requirements, and bundles together services that were previously billed separately.
CoachCare will manage the entire transition process from CCM to APCM for your patients, ensuring a seamless experience for both your practice and patients. Our care teams, who already have established relationships with your CCM patients, will handle all outreach and education about the enhanced APCM services during their regular patient interactions. We will obtain and document the required APCM consent, and explain the expanded benefits, while emphasizing the continued relationship with your practice as their primary care provider.
Have further questions? Get in touch.
Join CoachCare for an introductory session on Medicare’s new Advanced Primary Care Management (APCM) payment model, proposed to launch in 2025, and how analytics data can drive care management and patient outcomes.
