Chronic Care Management

The program that pays for time, and pays nothing when the time cannot be proven.

CCM has paid since January 2015, and Medicare payments for it grew substantially between 2019 and 2024. It is also the care-management program now under active federal audit. Both facts have the same cause: everything turns on documented minutes.

Scan my panel for CCM Compare with APCM

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What it pays

A base code, two add-ons, and a separate track for complexity

Unlike APCM, there are no levels set by the patient. The amount is set by how many documented minutes of clinical staff time the month contains — which is why the ceiling is high and the floor is zero.

Standard CCM

Most common

99490First 20 minutes of clinical staff time$66.13
99439Each additional 20 minutes, billable twice$50.44

$167.01 / month

A sixty-minute month, fully documented: the base code plus both add-ons. More than the top APCM level pays — if you can substantiate every minute.

Complex CCM

99487Complex CCM, first 60 minutes$144.29
99489Complex CCM, each additional 30 minutes$78.16

Complex CCM requires moderate or high complexity medical decision making and a sixty-minute floor rather than twenty. For a given patient-month you bill standard or complex, never both.

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

Nineteen minutes pays the same as zero minutes

This is the arithmetic that quietly kills CCM programs. A month where your staff genuinely managed the patient but logged nineteen documented minutes produces no claim at all. The work was real. The revenue is not.

Practices rarely lose CCM because they fail to qualify. They lose it because minutes get reconstructed at month end from memory, or never captured at all, and a program billed seven months out of twelve stops being worth running.

That is the machinery ITAS absorbs — not the medicine, and not the relationship. The part that decides whether a month you already worked is a month you can bill.

Time captured as the work happens
Logged at the moment of the call or the coordination, with date, duration, and clinical description attached — not reassembled from memory on the 30th.
A running total against the threshold
Every enrolled patient carries a live count toward twenty, forty, and sixty minutes, so a short month is visible while it can still be closed.
Short months flagged, not guessed at
A month that stays under the threshold does not present as billable, and it says why. Holding a month is cheaper than defending it.
The care plan kept current
Maintained in your certified EHR, versioned as conditions and medications change, with a copy available to the patient.
Consent captured before the first bill
Program-specific and dated, with cost-sharing and the single-biller rule on record, scripted for whoever is at the front desk.
RPM minutes kept separate
When a patient is on both programs, the same minute is never counted twice. The programs stack; the time does not.

Active enforcement

CCM is under federal audit right now

On March 16, 2026 the HHS Office of Inspector General opened a Work Plan audit of Medicare Part B payments for CCM, project OAS-26-09-007. Its stated objective is to review payments at risk of noncompliance with the multiple-chronic-condition requirement. It runs into FY2028.

This is not a proposed rule or a hypothetical. Two earlier OIG reviews, published in 2019 and 2021, already found Medicare paying for CCM services that did not meet the requirements. What is different now is that the audit was prompted by how much the program has grown — which means the sample is going to include ordinary small practices, not just outliers.

Eligibility tied to risk

Auditors are checking whether the record connects two or more chronic conditions to the risk of decline — not whether two diagnoses appear somewhere in the chart.

Time you can substantiate

Rounded entries, time credited to administrative rather than clinical staff, and minutes that overlap another billed service are all exposed.

A care plan that is actually specific

Individual conditions, current medications, and real coordination activity, with evidence it reached the patient.

Consent obtained before services

Dated, program-specific, and in place before the first month you bill.

Every one of those four is a gate in the software rather than a habit we ask your staff to maintain. How claims are gated.

The fine print that matters

What has to be true before a month is billable

CCM's requirements are not complicated to read. They are difficult to hold in place every month for every enrolled patient, which is a different problem and the one that decides whether the program survives.

01
Two or more chronic conditions
Expected to last at least twelve months, or until the patient dies.
02
Conditions that carry real risk
Placing the patient at significant risk of death, acute exacerbation or decompensation, or functional decline — documented as risk, not inferred from a problem list.
03
An initiating visit
Required for new patients and for anyone not seen within the past year. An annual wellness visit, an IPPE, or a comprehensive E/M all qualify.
04
Consent on record before you bill
Covering cost-sharing, the fact that only one practitioner may bill per month, and the patient's right to stop at any time.
05
A patient-specific care plan
Comprehensive, held in certified EHR technology, shared with the patient, and revised as things actually change. Generic templates are the classic finding.
06
24/7 access and continuity
A designated member of the care team the patient can expect to reach, and a documented route for after-hours contact.
07
Twenty minutes of clinical staff time
Non-face-to-face, within the calendar month, under general supervision and directed by the billing practitioner.
08
One biller per patient per month
Verified before the claim goes out, the same way it is for APCM.

The second requirement is the one under audit

Two chronic diagnoses on a problem list is not the standard. The record has to show that those conditions place the patient at significant risk of death, acute exacerbation, or functional decline. That is precisely the link the OIG audit is testing, and it is the cheapest thing on this page to get right at enrolment rather than in response to a letter.

Stacking

What can and cannot share a month

Stacks with CCM

Remote patient monitoring. RPM sits outside the care-management 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 CCM

APCM for the same patient in the same month — APCM bundles CCM outright. Complex CCM and standard CCM are also mutually exclusive within a patient-month. 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.

CCM questions

What practices ask first

What happens in a month where we log seventeen minutes?

Nothing bills for that patient. The care happened and the claim does not exist — that is the whole risk of a time-based program. ITAS shows the running total against the twenty-minute threshold while the month is still open and can still be closed, and holds the month rather than presenting it as billable if it stays short.

Can we bill CCM and APCM for the same patient?

Not in the same calendar month. APCM bundles CCM, so you choose one per patient per month. It is a genuine per-patient decision with real dollars on both sides, and we model it across the panel instead of applying a blanket rule.

Does CCM stack with remote monitoring?

Yes. RPM sits outside the care-management bundle, so both can be billed for the same patient in the same month. The rule that matters: the same minute of clinical time can never be counted toward both programs. The programs stack; the time does not.

Can we bill standard and complex CCM together?

No. For a given patient-month you bill one or the other. Complex CCM carries a sixty-minute floor and requires moderate or high complexity medical decision making, so it is a different claim rather than an addition to the standard one.

Who is allowed to do the work?

Clinical staff, under general supervision, directed by the billing practitioner — which is what makes the program scalable for a small practice. There are separate codes for time a physician or NP performs personally, which we cover during the panel scan if that is how your practice runs.

What does the patient pay?

CCM is a Part B service, so after the deductible most beneficiaries owe 20% coinsurance — roughly $13.23 a month at the 99490 national rate. Qualified Medicare Beneficiaries cannot be billed cost-sharing at all. Cost-sharing is a real reason enrolment conversations stall, so the consent script addresses it directly rather than leaving it to the front desk.

Is the bundled G0511 code still an option?

No. G0511 was retired on October 1, 2025, and care-management programs now bill individually. If your billing workflow still routes care management through the legacy code, that is worth reviewing — some practices discovered the change through a denial rather than a bulletin.

Does ITAS satisfy the certified-EHR requirement?

Your certified EHR does. ITAS is an overlay, not a certified EHR, and we will not tell you otherwise. The care plan lives in the system you already run; what we add is keeping it current and provable.

Find out which patients belong on CCM and which belong on APCM

The answer is different across your panel, and getting it wrong at the patient level is how a program that should generate revenue generates denials instead.

Get a free panel scan

No EHR change. No commitment.