Advanced Primary Care Management

What it is

Advanced Primary Care Management (APCM) is a new Medicare benefit (CY 2025+) that replaces time-based CCM/PCM billing with a fixed monthly fee based on patient complexity. It is a population-health-style payment for primary care practices delivering comprehensive, continuous management.

APCM is billed per patient per month based on the patient's level (L1/L2/L3) — there is no minute threshold.

Who qualifies

• Patient is attributed to the practice (primary care relationship).
• Practice has 24/7 access to the medical record for the care team.
• One practitioner / care team bills APCM per patient per month.
• Patient consent on file.
• Patient is not concurrently enrolled in CCM or PCM by the same practice.
• Patient level (L1 / L2 / L3) is assessed at enrollment based on chronic-condition count + dual-eligibility (QMB) status.

Codes & when to bill them

Each billable code, with the requirements that must be on file to bill it.

• G0556APCM Level 1 — patients with 1 chronic condition or fewer, lower complexity.
  RequirementsPatient attributed to practice; consent on file; care plan; 24/7 access maintained.
• G0557APCM Level 2 — patients with 2 or more chronic conditions.
  RequirementsSame as G0556 plus 2+ active chronic problems documented.
• G0558APCM Level 3 — QMB-eligible (Medicare-Medicaid dual) patients.
  RequirementsSame as G0556 plus QMB status verified in MBI or payer file.

Documentation required every cycle

Each calendar month must show:

1. Active care management — documentation of any of: enhanced communication, 24/7 access, comprehensive care plan, transitions of care management, coordination with home/community providers, population health management.
2. Patient level assessment documenting the L1/L2/L3 determination at enrollment.
3. Patient consent on file with version, date, and capture method.
4. Annual care plan review.

What's new in CY 2026

CY 2026 retains the APCM levels and rates introduced in CY 2025. APCM remains mutually exclusive with CCM and PCM within the same practice.

Built-in patient consentWillowbridge exclusive

Every program ships with compliant, CY-2026 patient consent language — read verbatim into the in-app consent capture flow, captured with date + modality, and version-pinned to each claim, so the consent on file always matches the consent that was billed. No more chasing signatures or re-papering when the rule changes.