Advanced Primary Care Management
A flat monthly payment for being the practice that actually manages the patient.
APCM has existed since January 2025. It pays every month, per patient, with no minute tracking — and most independent practices still do not bill it. Not because they fail to qualify, but because the program is made of operations rather than encounters.
What it pays
Three levels, set by the patient in front of you
The level is determined by chronic-condition count and, at the top tier, by whether the patient is a Qualified Medicare Beneficiary. Every level is billable once per patient per calendar month, by exactly one practitioner.
Level 1
$16.37 / month
Zero or one chronic condition. The lowest tier, and rarely where the volume is.
Level 2
$53.78 / month
Two or more chronic conditions expected to last at least twelve months, placing the patient at significant risk of death, acute exacerbation, decompensation, or functional decline. This is where most of a primary care panel lands.
Level 3
$117.24 / month
Two or more chronic conditions and Qualified Medicare Beneficiary status. Pays the most and costs the patient nothing — QMBs may not be billed cost-sharing.
CY2026 published national averages before locality adjustment. Your actual payment varies with your geographic adjustment factor and the current fee schedule. Verify against CMS before billing.
The real obstacle
It is not a coding problem. It is an operations problem.
Nothing about APCM is hard to understand. What makes it hard is that it has to happen every month, for every enrolled patient, whether or not anyone walked through your door — and it has to leave a documented trail behind it.
That is the work ITAS absorbs. Not the medicine, and not the relationship — the recurring machinery that determines whether a month you already worked is a month you can bill.
Consent, captured and provable
Program-specific, dated, with the cost-sharing disclosure and the single-biller rule on record. Scripted for whoever is at the front desk.
Monthly touchpoints that actually happen
Outreach drafted and queued against the panel, not left to whoever remembers.
The care plan, kept current
Maintained in your certified EHR, versioned, and available to the patient.
Transitions caught inside the window
Post-discharge and post-ED follow-up flagged against the seven-day requirement instead of discovered later.
Population view, not patient-by-patient
Care-gap analysis and risk stratification across the whole panel — an element in its own right.
One biller, verified
Eligibility and claims cross-checks before the claim goes out, because only one practitioner can bill APCM per month.
The fine print that matters
Twelve capabilities you must genuinely have
APCM replaces time thresholds with capability requirements. You are not asked to deliver every element to every patient every month — you are asked to actually be able to. Submitting the claim attests that you can.
- 01
Consent and patient information
Program-specific, dated, documented before services begin.
- 02
Initiating visit
Required for new patients or anyone not seen in three years. Can happen at an E/M, an annual wellness visit, or an IPPE.
- 03
24/7 access to the care team
Including a documented route for after-hours contact.
- 04
Continuity of care
A designated member of the care team the patient can expect to reach.
- 05
Comprehensive care management
Needs assessment, preventive services, medication reconciliation, self-management support.
- 06
Electronic care plan in certified EHR technology
Accessible inside and outside the practice, with a copy available to the patient or caregiver.
- 07
Care transitions
Referral management and follow-up after an emergency visit or discharge within seven calendar days where indicated.
- 08
Home and community coordination
Documented communication about psychosocial needs, goals, and preferences.
- 09
Enhanced communication
Portal or email access, remote evaluation, e-visits, virtual check-ins.
- 10
Population-level management
Care-gap analysis and risk stratification across the panel, not just the patient in the room.
- 11
Performance measurement
Primary-care quality, total cost of care, and meaningful use of certified EHR technology.
- 12
Quality reporting participation
A MIPS Value Pathway, or participation in Shared Savings, ACO REACH, Making Care Primary, or Primary Care First.
The certified-EHR elements are the ones practices trip on
Two of these elements — the electronic care plan and the performance-reporting requirement — depend on certified EHR technology and quality-program participation. ITAS is an overlay and is not itself a certified EHR. We check these against what you already run before anyone signs anything, because discovering it later is how a program gets unwound.
Stacking
What can and cannot share a month
Stacks with APCM
Remote patient monitoring. RPM sits outside the APCM bundle, so both can be billed for the same patient in the same month. The one rule that matters: the same minute of clinical time can never be counted toward both.
Mutually exclusive with APCM
CCM, PCM, and TCM for the same patient in the same month, along with interprofessional consults, virtual check-ins, remote evaluation, and online digital E/M. APCM bundles all of them. Choosing between APCM and CCM for a given patient is a real decision with real dollars on both sides.
We model this per patient during the panel scan rather than applying a blanket rule. How we think about APCM versus CCM.
APCM questions
What practices ask first
Do we have to track minutes for APCM?
Can we bill APCM and CCM in the same month?
Does our existing CCM consent carry over?
What does the patient pay?
Does ITAS satisfy the certified EHR requirement?
Which specialties can bill it?
Find out how many of your patients qualify today
Most practices are surprised twice: by how many patients meet the two-chronic-condition bar, and by how many are in the tier that costs the patient nothing.
No EHR change. No commitment.