2026 Billing Workflow Matrix

APCM + Behavioral Health + RPM/RTM

Quick reference for practice leaders and billers. Use this table at month-end before claims go out. Sources: CMS APCM page, CY 2026 PFS Final Rule Fact Sheet, and MLN Telehealth and RPM guidance.

Scenario	Allowed?	Codes Involved	Evidence Required	Pre-Claim Gotchas
1. APCM alone	Yes	G0556 / G0557 / G0558	Consent and initiating-visit logic documented 24/7 access and continuity with designated clinician/team Care plan updated this month (problems/goals, meds, transitions, population management)	Only one APCM base code per patient per month Make sure APCM documentation stands alone in an audit
2. APCM + BH add-on	Yes (with conditions)	APCM base (G0556/57/58) + BH add-on (G0568/G0569/G0570)	Same practitioner bills APCM and BH add-on in the same month CoCM/BHI-like activities documented (screenings, care-manager notes, case review, outcomes) BH work clearly tied to the APCM billing month	Do not bill BH add-on without APCM base in the same month Do not use different practitioners for APCM and BH add-on Do not double-bill legacy CoCM/BHI for the same patient/month
3. APCM + RPM	Yes (parallel)	APCM base + RPM device and management codes	APCM criteria met RPM medical necessity documented (diagnosis and rationale) Correct day bucket (2-15 vs 16-30) and time bucket (10-19 vs 20+) RPM evidence (days/time/actions) documented separately from APCM	One RPM billing practitioner per patient / 30-day period Do not reuse APCM coordination time as RPM management time Ensure selected RPM CPT matches documented days/time
4. APCM + RTM	Yes (parallel)	APCM base + RTM device and management codes	APCM evidence present RTM medical necessity documented for therapeutic/non-physiologic data RTM days/time consistent with selected RTM CPT	Do not bill RTM and RPM together Keep RTM evidence separate from APCM documentation Validate supervision and incident-to requirements
5. APCM + BH add-on + RPM	Yes (highest complexity)	APCM base + BH add-on + RPM device/management codes	All APCM requirements satisfied BH add-on work documented per add-on rules RPM evidence documented per day/time requirements APCM, BH, and RPM documentation streams are clearly separated	Enforce same-practitioner rule for APCM + BH add-on Enforce RPM practitioner exclusivity Prevent double counting APCM/BH work as RPM time
6. RPM or RTM only (no APCM)	Yes	RPM or RTM device and management codes	Established-patient and medical-necessity documentation Device assignment, day counts, management time, and actions documented For RTM, therapy-oriented self-reported data stream is in place	One RPM practitioner per 30-day period No RPM + RTM pairing Do not reuse work that is already billed under another program
7. BH add-on without APCM (or with different practitioner)	No	BH add-on billed without APCM base, or by a different practitioner	BH documentation exists but APCM base is absent that month, or BH add-on is billed by someone other than the APCM practitioner	Treat as do-not-bill/high-risk scenario Correct by adding valid APCM base under same practitioner or remove BH add-on Validator should hard-fail this configuration

This matrix is a planning aid. Confirm current CMS/MLN guidance and your MAC edits before billing.

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