Billing Two Care Management Services in the Same Month
Medicare now pays separately for a dozen monthly, largely non-face-to-face services, and a patient with several conditions may plausibly qualify for four of them at once. The question of which can be billed together in one month gets answered badly more often than almost anything else in this part of the program — usually by repeating a restriction CMS removed, or one it proposed and never finalized. The real answer is short: one principle governs, and there is a specific and current list of exceptions to it.
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Key takeaways
- The governing principle is that the same time and effort cannot be counted toward more than one service. CMS restates it in nearly every rulemaking that touches these codes.
- The one broad restriction currently in force concerns advanced primary care management: the services CMS identified as substantially duplicative of it may not be billed for a patient in the same month by the practitioner furnishing it.
- That restriction stops at the individual practitioner. CMS proposed extending it across the whole practice and expressly declined to finalize that — so a specialist in the same group may still bill.
- The long list of codes that could not be billed with transitional care management has been dismantled across three rulemakings. Most of it is gone.
- CMS has expressly permitted remote monitoring alongside chronic care management, transitional care management, principal care management, chronic pain management and behavioral health integration — and its own restatement of that permission cites the wrong Federal Register volume.
- Cost sharing applies to each service independently, so a month carrying three of these services carries three patient obligations.
The principle everything else is an exception to
CMS has one rule here and it has stated it in materially the same words for a decade: where two of these services are billed for the same patient in the same period, the time and effort involved in furnishing them cannot be counted more than once, each service's own requirements have to be met independently, and each has to be reasonable and necessary.
It is worth noticing how much work that principle does, because it explains why so few hard prohibitions exist. Two monthly services describing different work, delivered by different people, documented separately, are not duplicative in any sense Medicare cares about — the payment for each buys something the other did not. What Medicare is guarding against is a single block of staff time being billed twice under two names, and a rule against double-counting addresses that directly without needing a list.
The corollary practices forget
The one broad restriction in force
When CMS created advanced primary care management for CY 2025, it deliberately built the new codes to absorb the elements of several existing services. That created a genuine duplication risk, and CMS addressed it by identifying the overlapping services and restricting them.
The services it identified are chronic care management, principal care management, transitional care management, interprofessional consultation, remote evaluation of patient videos or images, virtual check-in, and e-visits. Those may not be billed for a patient in the same month as advanced primary care management by the same practitioner. CMS layered a second constraint on top: only one practitioner may furnish the advanced primary care management service for a patient in a month at all.
The restriction that was proposed and never finalized
The rest of the family CMS considered and left alone. Behavioral health integration, including the psychiatric collaborative care model, community health integration, principal illness navigation and its peer support variant, the social determinants of health risk assessment, remote physiologic monitoring and remote therapeutic monitoring may all be billed concurrently with advanced primary care management. CMS's reasoning was that these complement the newer service rather than duplicating it: they are sufficiently different in the nature and extent of the interventions and in the qualifications of the people delivering them, and they are not part of the core elements of advanced primary care. The usual conditions attach — requirements met, medically necessary, time and effort not counted twice.
The restrictions that expired, and why they are still quoted
Transitional care management has the longest history of concurrency restrictions in this family, and almost all of it has been undone. Following that history is the fastest way to understand why so much published guidance on this subject is wrong.
2013 — a list of 57 codes
When CMS established payment for transitional care management, it identified a list of 57 HCPCS codes that could not be billed concurrently with it because of potential duplication of services. That list is the ancestor of most of the prohibitions still circulating.CY 2020 — 16 codes released
Observing that use of transitional care management was low relative to the number of beneficiaries with eligible discharges, and that more use of the service could improve outcomes, CMS finalized a policy allowing concurrent billing with 16 of the actively priced codes during the period the service covers. It said at the time that it would keep refining the policy through rulemaking.CY 2021 — 14 more, plus a chronic care management code
CMS removed 14 further actively priced codes from the remaining list, stating that no overlap existed that would warrant preventing concurrent reporting. In the same rule it allowed HCPCS code G2058 — finalized as CPT code 99439, a chronic care management code — to be billed concurrently with transitional care management when reasonable and necessary, and restated that the minutes counted for one may not also be counted toward the other.Since — CMS summarizing its own position
Revisiting the question in a later rulemaking, CMS characterized the result plainly: transitional care management may be billed concurrently with other care management codes when relevant, medically necessary, and not duplicative. That is a different starting posture from the one the 2013 list implies.
Why the old rule outlives the new one
What CMS has expressly allowed
Several pairings have been settled directly, in response to questions from commenters. These are the most useful statements in the whole subject because they are permissions rather than silences — a practice does not have to reason its way to them.
| Pairing | CMS's position | Where it was decided |
|---|---|---|
| Remote physiologic or remote therapeutic monitoring with chronic care management, transitional care management, principal care management, chronic pain management, or behavioral health integration | Permitted. | CY 2023 Physician Fee Schedule final rule — but note the citation problem described below. |
| Chronic pain management with remote monitoring | Permitted. CMS noted these are distinct types of service although the eligible patient populations may overlap, and that cost sharing applies to each independently. | CY 2023 final rule, 87 FR 69538. |
| Chronic pain management with chronic care management, transitional care management, or behavioral health integration | Permitted where each service's requirements are met, with the reminder that time spent on one may not represent time spent on another. | CY 2023 final rule, 87 FR 69544. |
| Behavioral health integration and the psychiatric collaborative care model with advanced primary care management | Permitted. CMS answered a direct question about the collaborative care codes and confirmed they can be billed concurrently when all applicable requirements for both are met. | CY 2025 final rule, 89 FR 97896. |
| Interprofessional consultation with advanced primary care management | Permitted, with a caveat: because only one practitioner may furnish the monthly service for a patient, the consulting practitioner must not also be furnishing it. | CY 2025 final rule. |
| Chronic care management, principal care management, transitional care management, interprofessional consultation, remote evaluation of videos or images, virtual check-in, or e-visits with advanced primary care management | Not by the practitioner furnishing advanced primary care management. Permitted in the same month by a different practitioner, including one in the same practice, where medically necessary. | CY 2025 final rule, 89 FR 97896. |
| Remote physiologic with remote therapeutic monitoring | Not permitted for now. Commenters asked for it in the CY 2026 rulemaking and CMS said it would consider the request in future rulemaking — which is a refusal for the present. | CY 2026 final rule, 90 FR 49397. |
This table records what CMS has decided under the Physician Fee Schedule. Medicare Advantage plans and commercial payers set their own rules and are confirmed separately.
A citation to check rather than copy
One further nuance is worth knowing because it shows that the code book and Medicare payment policy can diverge. Asked about two remote monitoring codes that the code book instructs should not be reported in conjunction with one another, CMS took the view that they describe different services and could, if reasonable and necessary, be reported for the same patient — provided the same time was not used to meet the criteria for both. Where a code book parenthetical and a Medicare payment policy disagree, they are answering different questions, and a practice needs to know which one its payer is applying.
How to decide a specific month
The order of these questions matters, because the first one disposes of most cases without any research.
Is the same time being counted twice?
If one block of staff time is what makes both services billable, stop. That is the rule CMS applies everywhere in this family, and no permission survives it. If the two services rest on genuinely separate work, separately documented, continue.Is advanced primary care management one of them?
If so, identify the practitioner furnishing it, and ask whether the other service is on the duplicative list and whether the same practitioner is billing it. Same practitioner plus a listed service means no. A different practitioner, even in the same practice, means the restriction does not apply.Does each service independently meet its own requirements?
Consent, an initiating visit where one is required, the supervision conditions, and the code's own elements all have to hold for each service on its own terms. A service that would not be billable alone does not become billable by being paired.Is the internal rule you are about to apply from a live rulemaking?
Where a claim scrubber or a policy document blocks the pairing, trace the block to a rule. A surprising proportion of them trace to the 2013 transitional care management list or to the same-practice restriction CMS declined to finalize — neither of which is in force.Confirm the payer
Everything above is Physician Fee Schedule policy. A Medicare Advantage plan or a commercial payer may take a different position, and its position is the one that decides the claim.
The two services most often at the centre of this question are chronic care management billing and remote patient monitoring billing, and each has its own requirements that have to hold before any of this becomes relevant.
Common questions
Can chronic care management and transitional care management be billed in the same month?
Generally yes, subject to the usual conditions. The prohibition most people remember comes from the 2013 rulemaking that established transitional care management, which identified a list of 57 codes that could not be billed concurrently with it. CMS has dismantled most of that list: it released 16 actively priced codes in the CY 2020 final rule and 14 more in CY 2021, and in the same CY 2021 rule it specifically allowed a chronic care management code — HCPCS G2058, finalized as CPT 99439 — to be billed concurrently with transitional care management when reasonable and necessary. CMS has since summarized its own position as allowing transitional care management concurrently with other care management codes when relevant, medically necessary, and not duplicative. The standing limit is that the minutes counted toward one service cannot also be counted toward the other.
Can a specialist in the same practice bill principal care management while a colleague bills advanced primary care management?
Yes. This is the single most commonly misapplied rule in the subject. CMS proposed to bar the duplicative services when billed by any practitioner in the same practice as the one furnishing advanced primary care management, and after commenters objected it declined to finalize that. Its words were that it is not finalizing the concurrent billing restrictions except with respect to the one practitioner who is furnishing advanced primary care management. The services it listed may therefore be billed in the same month by a practitioner other than that one, including a colleague in the same group, where medically necessary. The example CMS itself gave involved an oncologist furnishing transitional care management while another practitioner in the same practice continued advanced primary care management for the same patient.
Can remote patient monitoring be billed alongside the other monthly care management services?
Yes. In the CY 2023 Physician Fee Schedule final rule CMS clarified that remote physiologic and remote therapeutic monitoring could be billed concurrently with chronic care management, transitional care management, principal care management, chronic pain management, or behavioral health integration, provided each service's requirements are met, the services are medically reasonable and necessary, and the same time and effort is not counted more than once. Remote monitoring may also be billed alongside advanced primary care management, which CMS confirmed when it created those codes. One caution when verifying this: CMS prints the citation for the CY 2023 clarification as volume 86 of the Federal Register in both the CY 2024 final rule and the CY 2027 proposed rule, and the correct volume is 87.
Can two practitioners bill the same monthly care management service for one patient?
No, for the services that carry an exclusivity condition. Only one practitioner may furnish and be paid for advanced primary care management for a patient in a month, and CMS requires that the patient be told so when consent is taken. The same one-practitioner logic applies to remote monitoring, where CMS has stated that the services associated with all of a patient's devices can be billed by only one practitioner and only once per patient per period. Where two practices discover they have both enrolled a patient, the resolution is a matter of who holds consent rather than who did more work.
Does the patient pay more when several of these services are billed in one month?
Yes. CMS has stated directly that cost sharing applies to each service independently, so a month carrying three separately billable monthly services carries three separate patient obligations. Because these services are largely non-face-to-face, the patient may not perceive them as three distinct things, which is why CMS built a cost-sharing disclosure into the consent requirements for these services rather than leaving it to the statement. Practices that stack several of these services and do not revisit that conversation generate a predictable volume of complaints.
Where does the rule against double-counting time actually come from?
It is a policy CMS states and restates in rulemaking rather than a codified regulation. It appears in the CY 2021 final rule as the requirement that minutes counted for transitional care management cannot also be counted toward other services; in the CY 2023 final rule as the reiteration that time used in reporting chronic pain management may not represent time spent in any other reported service; and in the CY 2025 final rule as the condition attached to every permission it granted around advanced primary care management — that the time and effort involved not be counted more than once. Its consistency across rulemakings is what makes it the safest thing to reason from when a specific pairing has never been addressed.
Terms used here
Definitions for the vocabulary this article assumes.
Continue learning
Where to go next.
Medicare billing
The cluster this sits in — how the program is structured, billed, and denied.
Chronic care management billing
The service at the centre of most of these questions, and the alternative CMS built beside it.
Remote patient monitoring billing
The most permissive member of the family, and the classification that governs it.
Collaborative care model billing
The behavioral health service that may be billed alongside advanced primary care management.
Medicare overpayments and recoupment
What happens when a pairing turns out not to have been payable after all.
Primary care billing
Where these longitudinal programs sit inside a whole specialty revenue cycle.
Authoritative sources
- CY 2025 Physician Fee Schedule final rule, 89 FR 97710 — duplicative services and concurrent billing restrictions (at 97894 through 97896) (opens in a new tab)
The rulemaking that set the only broad restriction currently in force. It identifies the services CMS considered substantially duplicative of advanced primary care management — chronic care management, principal care management, transitional care management, interprofessional consultation, remote evaluation of patient videos or images, virtual check-in and e-visits — and finalizes at 97896 that they may not be billed for a patient in the same month by the practitioner furnishing advanced primary care management, while expressly declining to finalize the wider same-practice restriction it had proposed. The same discussion records the oncologist example, confirms that behavioral health integration and the psychiatric collaborative care model may be billed concurrently, and finalizes concurrent billing for community health integration, principal illness navigation and its peer support variant, the social determinants of health risk assessment, and remote physiologic and remote therapeutic monitoring.
- CY 2021 Physician Fee Schedule final rule, 85 FR 84472 — transitional care management (at 84546 through 84547) (opens in a new tab)
Records the history of the transitional care management exclusion list: the 57 HCPCS codes identified in the CY 2013 final rule at 77 FR 68990, the 16 actively priced codes released in the CY 2020 final rule at 84 FR 62685 through 62687, and the 14 further codes removed for CY 2021 together with HCPCS code G2058 — finalized as CPT code 99439 — which CMS allowed to be billed concurrently with transitional care management when reasonable and necessary. It also states the principle that the minutes counted for transitional care management cannot also be counted toward other services.
- CY 2023 Physician Fee Schedule final rule, 87 FR 69404 — concurrent billing of the care management services (at 69528 through 69544) (opens in a new tab)
The rule later restatements mean to cite, and the source of the broadest set of express permissions. At 69528 it reiterates the policy against double-counting time. At 69538 it permits the chronic pain management codes for the same patient in the same month as remote physiologic or remote therapeutic monitoring, notes that the time and effort cannot be counted more than once, and states that cost sharing applies to each service independently. At 69544 it permits chronic pain management in the same month as chronic care management, transitional care management and behavioral health integration where each service's requirements are met.
- CY 2024 Physician Fee Schedule final rule, 88 FR 78818 — clarifications for remote monitoring services (at 78882) (opens in a new tab)
CMS's consolidated restatement that the CY 2023 rule permitted remote physiologic and remote therapeutic monitoring concurrently with chronic care management, transitional care management, principal care management, chronic pain management and behavioral health integration. This page is where the citation for that clarification is printed as volume 86 rather than volume 87 — an error CMS has since carried into the CY 2027 proposed rule.
- CY 2026 Physician Fee Schedule final rule, 90 FR 49266 — remote monitoring (at 49396 through 49397) and behavioral health integration add-ons (at 49464 through 49470) (opens in a new tab)
Records CMS's refusal, for the present, of commenter requests to allow remote physiologic and remote therapeutic monitoring to be billed concurrently, to pay for multiple devices, and to permit billing during the global period, each deferred to future rulemaking. Separately establishes the optional add-on codes that let behavioral health integration and the psychiatric collaborative care model be furnished alongside advanced primary care management without their usual time documentation when the base code is reported by the same practitioner in the same month.
- 42 CFR 410.26 — Services and supplies incident to a physician's professional services: Conditions (opens in a new tab)
The codified provision underlying this whole family. Paragraph (b)(5) allows designated care management services to be furnished under general supervision rather than direct supervision, and reserves the right to bill Medicare for an incident-to service to the supervising practitioner alone — which is why the question of who may bill a given month resolves to a single practitioner per service rather than to whoever performed the work.