Chronic Care Management Billing
Chronic care management is billed monthly, for work done when the patient is not in the room, by a practice that has to prove afterwards that the work happened. Nearly every published guide to it opens with a number of minutes. That number is real, but it is not a Medicare rule — it is content of the code descriptor, and Medicare adopts it by reference. The requirements that are Medicare's are different ones: consent recorded before the service starts, an initiating visit for new patients, supervision that decides whose name goes on the claim, and a hard limit of one billing practitioner per patient per calendar month.
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Key takeaways
- Beneficiary consent is documented in the medical record as a condition of payment. Written consent is not required — verbal consent, documented, is sufficient — and a new consent is needed when the billing practitioner changes.
- An initiating visit is required for new patients only. A level 2 through 5 evaluation and management visit, the initial preventive physical examination, or a transitional care management service can serve as it.
- Chronic care management is a designated care management service under 42 CFR 410.26(b)(5), so clinical staff may furnish it under general supervision — but only the supervising practitioner may bill it.
- Only one practitioner may furnish and be paid for the monthly service for a given patient, and the patient has to be told that when consent is taken.
- No Medicare regulation states a minimum time or a minimum number of chronic conditions. Those figures are code descriptor content, and the current code book is where the binding version lives.
- Since 1 January 2025 there is a Medicare-designed alternative — advanced primary care management — that removed the minute counting entirely and substituted a quality reporting obligation. The same practitioner cannot bill both for the same patient in the same month.
What Medicare actually requires
Chronic care management sits in a family of monthly, largely non-face-to-face services that Medicare pays for separately from visits. The requirements CMS sets for it are procedural rather than quantitative, and they are stated most completely not in the rulemaking that created the service but in the CY 2025 rulemaking that built its successor — where CMS set out each requirement for advanced primary care management by reference to what it already required for chronic care management.
- Consent, documented, as a condition of payment
- The beneficiary's consent to receive the service is documented in the medical record, and CMS describes that as a condition of payment. Written consent is not necessary; a practitioner may take it in writing if it prefers. What has to be conveyed is specific: that the service is available, that cost sharing usually applies, that only one practitioner can furnish and be paid for the service in a given month, that consenting does not limit the patient's right to receive care from other practitioners, that the service is ongoing and monthly, and that the patient may stop at any time. The practitioner records that this was explained and whether the patient accepted or declined.
- Consent follows the practitioner, not the patient
- A new consent is required if the practitioner who furnishes and bills the service changes. CMS described that as in line with the consent requirements for the other care management services. It follows that a practice acquiring a panel does not inherit consent along with the charts.
- An initiating visit — for new patients only
- The initiating visit requirement applies to new patients rather than to everyone entering the service. It establishes the relationship with the billing practitioner, ensures the patient is assessed before the monthly service begins, and produces the information the care plan is built from. Describing the set in order to adopt it for the newer service, CMS identified a level 2 through 5 evaluation and management visit, the initial preventive physical examination, or a transitional care management service as able to serve as the initiating visit for chronic care management, and it may be furnished in person or as a Medicare telehealth service. Consent may be taken at that visit but does not have to be.
- Supervision decides whose claim it is
- Chronic care management is a designated care management service, which is a term of art in the supervision regulation. Under 42 CFR 410.26(b)(5), designated care management services may be furnished under general supervision — the practitioner's overall direction and control, without requiring presence — rather than the direct supervision otherwise required for services furnished incident to a practitioner's own. The same paragraph adds the constraint practices miss: the supervising practitioner need not be the one treating the patient more broadly, but only the supervising practitioner may bill Medicare for the service.
One practitioner per patient per month is a consent term
The requirement that is not Medicare's
Ask what chronic care management requires and almost every answer available online begins with a quantity of clinical staff time per calendar month and a number of qualifying chronic conditions. Both figures are genuine conditions of billing the codes. Neither is a Medicare regulation, and the difference matters more than it sounds.
Those figures are content of the CPT code descriptors. Medicare's role is to adopt the codes and pay for them; the quantities that define what each code describes are set by the American Medical Association's editorial process, not by rulemaking. That has three consequences a billing operation can act on.
- The binding text is in the current-year code book, and it changes there rather than in the Federal Register. A figure remembered from a training deck two years old has no expiry date printed on it.
- Searching Medicare regulations for the requirement will not find it. Practices sometimes conclude from that search that the requirement is soft. It is not — it is simply located somewhere else.
- The quantities are also why the service is unpopular relative to how many patients qualify for it, which is the problem CMS set out to solve when it built the alternative described in the next section.
Where the CFR does name these codes, and what for
The alternative Medicare built, and what it costs to take it
For services furnished on or after 1 January 2025, Medicare pays separately for advanced primary care management under HCPCS codes G0556, G0557 and G0558. It is not a neighbouring service. It is CMS's answer to the objection that the documentation burden of the existing care management codes was suppressing their use — and the specific burden it removed is the one this article has been describing.
| Dimension | Chronic care management | Advanced primary care management |
|---|---|---|
| Counting and documenting minutes | Required, as a condition of the codes. | Not required. CMS removed the requirement, and stated in the CY 2026 rulemaking that the codes do not require the counting of minutes to bill. |
| What replaced it | — | A quality obligation: a practitioner billing these codes reports the Value in Primary Care MIPS Value Pathway. CMS added it in response to its own concern about auditability once the minute record was gone. |
| Consent | Documented in the medical record; verbal is sufficient; a new consent when the billing practitioner changes. | The same, and CMS was explicit that an existing consent does not carry over — a patient moving from chronic care management to the newer service gives a new consent. |
| Initiating visit | Required for new patients. | Required for new patients, and the same services may serve as it — plus the Medicare annual wellness visit, which CMS added on finalization after commenters pointed out that leaving it off had been an oversight. CMS also refused to let a different practitioner furnish it: the initiating visit has to come from the practitioner who will furnish the monthly service. |
| Who counts as needing one | New patients. CMS did not restate the exceptions for this service. | Narrower than it first appears. CMS finalized that no initiating visit is required for a patient the practice has seen within a stated lookback, for a patient who has received another care management service from the practice within a shorter one, or for a beneficiary already attributed to the practitioner's accountable care organization or CMS Innovation Center model through an established care relationship. The lookback periods themselves are at 89 FR 97881. |
| Billing both in one month | Not by the same practitioner. CMS finalized that the services it identified as substantially duplicative — chronic care management among them — may not be billed for a patient in the same month as advanced primary care management by the same practitioner. | The restriction runs one way only: another practitioner may bill the duplicative service in the same month where it is medically necessary. |
Both remain payable services. This is a choice a practice makes patient by patient and practitioner by practitioner, not a migration Medicare has scheduled.
The newer service also grew for CY 2026. CMS added optional add-on codes — G0568, G0569 and G0570 — that let a practice furnish behavioral health integration and psychiatric collaborative care alongside it without the time documentation those services otherwise require, when the base code is reported by the same practitioner in the same month. Those add-ons are themselves designated care management services under 42 CFR 410.26(b)(5), so the same general supervision rule reaches them. The underlying collaborative care model is unchanged; what changed is the documentation a primary care practice needs to bill it.
Uptake has been slower than CMS expected
Rural health clinics and federally qualified health centers
These facilities bill care management on a separate footing, and the regulation is unusually legible about it. Under 42 CFR 405.2464(c), rural health clinics and federally qualified health centers are paid for the non-face-to-face care management work involved in coordinating care, and the paragraph's subparagraphs read as a dated ledger of which services entered that payment and when — chronic care management from 1 January 2016, general behavioral health integration and the collaborative care model from 1 January 2018, principal care management from 1 January 2021, chronic pain management from 1 January 2023, remote monitoring and the health-related social needs services from 1 January 2024, and advanced primary care management for services furnished on or after 1 January 2025.
The supervision rule has its own counterpart for these settings. 42 CFR 405.2413(a)(5) and 405.2415(a)(5) provide that services furnished incident to transitional care management, general care management, the psychiatric collaborative care model and behavioral health services may be furnished under general supervision, rather than the direct supervision those sections otherwise require — the same relaxation § 410.26(b)(5) makes for physician practices, written separately for facilities.
What this means for the workflow
Audit the consent record before auditing the time record
Consent is where a program is most often thin, because it is taken once and then never revisited. Check that it exists in the chart, that what the patient was told is recorded, and — the one most likely to be missing — that a fresh consent was taken whenever the billing practitioner changed.Separate the two kinds of requirement in your internal policy
A practice policy that lists the minute count next to the consent requirement, both unsourced, teaches staff that they change in the same way and can be verified in the same place. They do not and cannot. Cite the code book for one and the rulemaking for the other.Decide the exclusivity question at enrolment
Only one practitioner is paid for the month, so the time to discover a competing enrolment is at consent, not at the end of the period. For patients who see several practices regularly, the enrolment conversation is the control.Price the documentation burden against the alternative
Where a practice already meets the practice-level conditions and is reporting quality data, the newer codes remove the minute record entirely. Where it is not, they add a reporting obligation it does not currently carry. This is a real trade rather than an upgrade, and it is decided per practitioner.Check what else was billed for the patient that month
Chronic care management can be billed alongside several of the other monthly services when each service's own requirements are met and the same time and effort is not counted twice, and cannot be billed alongside others at all. Which is which — and which of the widely quoted restrictions are actually still in force — is set out in billing two care management services in the same month. That question is worth settling before the period closes rather than on an overpayment demand afterwards.
Because these services are largely invisible to the patient, they generate a distinctive kind of complaint: a bill for a month in which the patient believes nothing happened. That is a cost sharing conversation the consent process is supposed to have had already, which is the practical reason CMS made the cost-sharing disclosure part of consent rather than leaving it to the statement.
Common questions
Does chronic care management require written consent from the patient?
No. CMS finalized that consent must be obtained at the initiation of the service and documented in the medical record, and stated expressly that written consent is not necessary, though a practitioner may obtain it in writing if it prefers. What matters is that the consent is documented and that the record shows the patient was told the relevant facts — that the service is available, that cost sharing usually applies, that only one practitioner can be paid for it in a month, that consent does not limit their right to see other practitioners, and that they may stop at any time.
Is a new consent needed if the patient changes practitioner within the practice?
Yes, where the practitioner who furnishes and bills the service changes. CMS stated that a new consent is required in that circumstance, and described the requirement as in line with the consent requirements for the other care management services. Because consent is to receive the service from a specific billing practitioner — the one who intends to be the continuing focal point for the patient's care — it does not transfer with the chart when the panel does.
Does every patient need an initiating visit?
No. The initiating visit requirement applies to new patients rather than to all patients entering the service. Where it does apply, CMS has identified a level 2 through 5 evaluation and management visit, the initial preventive physical examination, or a transitional care management service as able to serve as it, and it may be furnished either in person or as a Medicare telehealth service. For advanced primary care management, CMS finalized two refinements worth knowing because they show the direction of its thinking: the Medicare annual wellness visit may also serve as the initiating visit, which CMS added after commenters noticed it had been left out by oversight, and the initiating visit must be furnished by the practitioner who will go on to furnish the monthly service rather than by a colleague. Its purpose is to establish the relationship, ensure the patient is assessed before monthly management begins, and gather the information the care plan is built from; consent can be taken there but can also be taken separately.
Where does the minimum time requirement for chronic care management come from?
From the CPT code descriptors, not from Medicare regulation. The quantities that define these codes — the clinical staff time per calendar month and the number of qualifying chronic conditions — are set through the American Medical Association's editorial process, and Medicare adopts the codes as written. That is why searching the Code of Federal Regulations for the requirement does not find it: 42 CFR 410.26, 410.15, 405.2413, 405.2415, 405.2464 and 425.400 are the sections that address these services, and none states a minimum time or condition count. The current-year code book is where the binding language is, and this site does not reproduce it because the descriptor text is copyrighted.
Can clinical staff perform chronic care management work without the physician present?
Yes. Chronic care management is a designated care management service, and 42 CFR 410.26(b)(5) provides that designated care management services can be furnished under general supervision when provided incident to a practitioner's services, rather than under the direct supervision that paragraph otherwise requires. General supervision, defined at 42 CFR 410.26(a)(3), means the service is furnished under the practitioner's overall direction and control without requiring the practitioner's presence. The corresponding rules for rural health clinics and federally qualified health centers are at 42 CFR 405.2413(a)(5) and 405.2415(a)(5). In every case only the supervising practitioner may bill Medicare for the service.
Can chronic care management and advanced primary care management both be billed in the same month?
Not by the same practitioner. In the CY 2025 Physician Fee Schedule final rule CMS identified chronic care management among the services that substantially duplicate advanced primary care management, and finalized that those services may not be billed for a patient in the same month as advanced primary care management by the same practitioner. The restriction runs one way only: CMS declined to finalize a wider bar it had proposed, so another practitioner may bill the duplicative service for the same patient in the same month where it is medically necessary. A patient moving from one service to the other also gives a new consent, because CMS held that an existing chronic care management consent is not sufficient for the newer service.
Does chronic care management affect accountable care organization assignment?
Yes. 42 CFR 425.400 lists the chronic care management codes among the primary care services used to assign beneficiaries to Shared Savings Program accountable care organizations, along with the transitional care management, principal care management, advance care planning, behavioral health integration and advanced primary care management codes. That is a separate consequence from payment, decided in a different part of the regulations, and it is the reason a practice in a shared savings arrangement may value these services differently from one that is not.
Terms used here
Definitions for the vocabulary this article assumes.
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Where to go next.
Medicare billing
The cluster this sits in — how the program is structured, billed, and denied.
Remote patient monitoring billing
The other monthly care management service, and the classification that governs it.
Incident-to and split or shared billing
The supervision rules that decide whose name goes on work the clinical staff performed.
Medicare preventive services billing
Where the initial preventive physical examination that can serve as an initiating visit is billed.
Collaborative care model billing
The behavioral health service the newer add-on codes attach to.
Primary care billing
The specialty guide where these longitudinal programs sit inside a whole revenue cycle.
Authoritative sources
- CY 2025 Physician Fee Schedule final rule, 89 FR 97710 — advanced primary care management (at 97864 and 97880 through 97896) (opens in a new tab)
The rulemaking that created HCPCS codes G0556, G0557 and G0558 and, in doing so, stated the requirements for the existing care management services by reference. At 97864, the removal of the requirement to count and document minutes and the substitution of Value in Primary Care MIPS Value Pathway reporting. At 97880 through 97881, the consent requirements — documented in the medical record, written consent not necessary, a new consent when the billing practitioner changes, an existing chronic care management consent not sufficient for the newer service — and the initiating visit requirement for new patients, naming a level 2 through 5 E/M visit, the initial preventive physical examination or a transitional care management service, in person or as a Medicare telehealth service. At 97896, the finalized concurrent billing policy and CMS's decision not to finalize the wider restriction it had proposed.
- 42 CFR 410.26 — Services and supplies incident to a physician's professional services: Conditions (opens in a new tab)
Paragraph (b)(5) provides that designated care management services can be furnished under general supervision rather than the direct supervision otherwise required, that the supervising practitioner need not be the practitioner treating the patient more broadly, and that only the supervising practitioner may bill Medicare for incident-to services. General supervision is defined at paragraph (a)(3) and auxiliary personnel at paragraph (a)(1). The section states no time or condition threshold for any care management service.
- CY 2026 Physician Fee Schedule final rule, 90 FR 49266 — behavioral health integration add-on codes for advanced primary care management (at 49464 through 49470) (opens in a new tab)
Establishes HCPCS codes G0568, G0569 and G0570 as optional add-on services reported when the advanced primary care management base code is billed by the same practitioner in the same month, on the reasoning that the time-based documentation of the underlying behavioral health integration and collaborative care services was a barrier to their use. States that the base and add-on codes do not require the counting of minutes to bill, and that the add-ons are designated care management services at 42 CFR 410.26(b)(5) and so may be provided by auxiliary personnel under general supervision.
- 42 CFR 405.2464 — Payment rate for rural health clinics and federally qualified health centers (opens in a new tab)
Paragraph (c) provides that these facilities are paid for the non-face-to-face care management work involved in coordinating care, and its subparagraphs date each service into that payment: chronic care management from 1 January 2016 at (c)(1); the collaborative care model from 1 January 2018 at (c)(2); general behavioral health integration from 1 January 2018 at (c)(3); principal care management from 1 January 2021 at (c)(4); chronic pain management from 1 January 2023 at (c)(5); remote monitoring, community health integration and principal illness navigation from 1 January 2024 at (c)(6); and advanced primary care management for services furnished on or after 1 January 2025 at (c)(7).
- 42 CFR 405.2413 — Services and supplies incident to a physician's services in rural health clinics and federally qualified health centers (opens in a new tab)
Paragraph (a)(5) requires direct supervision for incident-to services in these settings, except that services and supplies furnished incident to transitional care management, general care management, the psychiatric collaborative care model and behavioral health services may be furnished under general supervision when furnished by auxiliary personnel as defined at 42 CFR 410.26(a)(1). The parallel provision for services incident to a nurse practitioner, physician assistant or certified nurse-midwife is at 42 CFR 405.2415(a)(5).
- 42 CFR 425.400 — Shared Savings Program: general rules for beneficiary assignment (opens in a new tab)
Paragraph (c)(1) enumerates the primary care services used to assign beneficiaries to accountable care organizations, with the list for performance year 2026 and subsequent years at paragraph (c)(1)(x). It names the chronic care management codes at (c)(1)(x)(A)(13) and (14) and at (c)(1)(x)(B)(12) and (23), together with the principal care management, transitional care management, advance care planning, behavioral health integration and advanced primary care management codes. This is the only place in the Code of Federal Regulations where these code numbers appear, and it uses them for beneficiary assignment rather than to set conditions of payment.