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APCM Readiness Checklist (2026)

Prepare your practice to bill the APCM monthly bundle, layer behavioral-health add-ons correctly, and keep RPM/RTM compliant under the new thresholds. Sources: public CMS + Federal Register.

What APCM is (30-second refresher)

APCM is a non-time-based, monthly bundle with three base HCPCS codes (G0556/G0557/G0558) you choose by patient complexity when monthly requirements are met. It replaces minute-tallying with longitudinal primary-care management requirements. [1]

What changed for 2026 (essentials only)

CMS finalized three optional behavioral-health add-on G-codes—billable in the same month by the same practitioner who reports the APCM base code; designed to be comparable to existing CoCM/BHI codes. Finalized as G0568, G0569, G0570. [2]
Remote-care updates + methodology (including OPPS use for some remote-monitoring services) and a −2.5% efficiency adjustment that does not apply to time-based services or services on the telehealth list. [2]

Readiness steps

Panel & continuity

Attribute each APCM patient to a named clinician/team; capture continuity touches monthly. [1]

Consent & initiating visit

Record one-time consent; confirm initiating-visit criterion (or qualifying prior service) per CMS APCM page. [1]

24/7 access & documentation

Demonstrate 24/7 urgent access and continuity; maintain an electronic, shareable, patient-centered care plan covering problems/goals, medications, transitions, population-management, and performance elements. [1]

RHC/FQHC specifics

RHCs/FQHCs: APCM BH add-ons are adopted; certain component reporting (e.g., CoCM/CTBS/Remote Evaluation) updated for 2026—confirm MAC instructions. [2]

Behavioral health inside APCM

When appropriate, add G0568/G0569/G0570 with APCM in the same month/same practitioner; align with CoCM/BHI activities without legacy minute thresholds (fact sheet confirms add-on; FR specifies codes). [2]

RPM/RTM alignment

For 2026, new/revised codes recognize 2–15 days device windows and 10-minute treatment-management increments (alongside traditional 16+ day / 20+ minute codes). Keep medical necessity, device-day counts, and time documentation distinct from APCM. [3]
Apply current general RPM constraints (e.g., one billing practitioner per patient per 30 days; RPM and RTM not together) unless CMS updates MLN. [4]

Efficiency & rates

Track whether target codes are exempt from the −2.5% efficiency adjustment; review CMS exempt-code list. [2]

Operational guardrails

Don’t double-count the same clinical work across APCM/BH add-on and RPM/RTM. Keep artifacts distinct (care-plan vs device-day logs vs management minutes). [2]
Validate supervision/telehealth policies (virtual direct supervision finalized where applicable). [2]

Go-live assets you should have on day one

APCM monthly note template (see companion asset).
BH add-on checklist embedded into the APCM note.
RPM/RTM evidence pack: device-day exports (2–15 or 16–30), time logs (10–19 or 20+), escalation documentation.
Pre-claim validator that blocks: BH add-on without APCM; RPM without required days/time; practitioner conflicts.

Sources (public)

This checklist summarizes public CMS materials and related sources. Always confirm with your MAC and payer bulletins prior to billing.