07 Nov 2024 | 3 MIN READ

CMS Opens the Door to More Virtual Care, Digital Health

The Centers for Medicare & Medicaid Services (CMS) has approved a new primary care model that incorporates virtual care and technology to meet patient needs. In the finalized 2025 Physician Fee Schedule, CMS introduced three new HCPCS codes for Advanced Primary Care Management (APCM), effective January 2025. These codes focus on physician-patient interactions at the patient’s preferred time and location, with billing based on monthly services rather than time spent.


The APCM codes bundle elements from existing Chronic Care Management (CCM) and Principal Care Management (PCM) codes with Communications Technology-Based Services (CTBS), including virtual check-ins and remote evaluations. Unlike CCM and PCM, the APCM codes are not time-based, allowing billing for care management services even when time requirements for CCM or PCM are not met.


The rule also expands the eligibility for non-physician providers, like nurse practitioners and physician assistants, to order and bill for APCM services as long as they are responsible for the patient’s primary care. However, providers must be cautious not to bill the APCM codes alongside overlapping services like virtual check-ins or interprofessional consults.


The three new APCM codes are:

G0556: For patients with one chronic condition

G0557: For patients with two or more chronic conditions

G0558: For patients with two or more chronic conditions and Qualified Medicare Beneficiary status


CMS plans to increase the valuation for G0556 starting in 2025, following feedback from providers. The new codes aim to improve access to high-quality primary care, simplify billing, and support primary care transformation through hybrid payment models. They also align with existing care coordination codes to drive accountable care.


To be eligible for reimbursement, providers must meet nine requirements, including patient consent, continuity of care, comprehensive care management, and enhanced communication opportunities. While these codes come with additional administrative requirements, they offer opportunities for practices to receive reimbursement for care management services they may already be providing. Ultimately, CMS aims to improve health equity, access to care, and population-level outcomes through these reforms.


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