What the CCM codes are
Chronic Care Management is the monthly Medicare service for patients with two or more chronic conditions expected to last at least 12 months or until death, and that put the patient at significant risk of death, acute exacerbation or decompensation, or functional decline. Six CPT codes bill it.
Three questions decide which one you report. Was the month complex or non-complex? Did clinical staff do the work, or did the billing practitioner do it personally? And how many minutes did it take? Unlike TCM, which is defined by required elements and has no minute threshold, CCM is a stopwatch service. If the month came up 3 minutes short, there is no claim.
The codes are cumulative across the calendar month, not per encounter. A nurse who spends 6 minutes on Tuesday, 9 on the 14th, and 8 on the 22nd has 23 minutes and a billable 99490.
The six CCM codes
CMS lays the family out by staff type and time in the June 2025 Medicare Learning Network booklet Chronic Care Management Services (MLN909188). Add-on codes carry a plus sign and cannot stand alone.
| Code | Who does the work | Time in the calendar month | 2026 national non-facility payment |
|---|---|---|---|
| 99490 | Clinical staff, directed by the billing practitioner | First 20 minutes | $66.13 |
| +99439 | Clinical staff | Each additional 20 minutes, up to two units | $50.44 |
| 99491 | The billing practitioner, personally | First 30 minutes | $89.18 |
| +99437 | The billing practitioner, personally | Each additional 30 minutes | $63.13 |
| 99487 | Clinical staff, complex CCM | First 60 minutes | $144.29 |
| +99489 | Clinical staff, complex CCM | Each additional 30 minutes | $78.16 |
Payment figures are 2026 Medicare national averages, calculated from the CMS CY2026 Physician Fee Schedule Relative Value File (January release) at the standard conversion factor of $33.4009. Clinicians who are qualifying participants in Advanced Alternative Payment Models are paid at $33.5675, which adds a few cents per code. Your locality rate will differ because of the geographic practice cost indices.
Non-complex versus complex CCM
Complex CCM asks for two things ordinary CCM does not: moderate to high complexity medical decision making by the billing practitioner, and 60 minutes of clinical staff time before anything is reportable. The patient population is the same two-or-more-chronic-conditions group.
You cannot report both in the same calendar month. That forces a choice at month end, and the arithmetic is not what most teams assume. A 60-minute month billed as complex CCM pays $144.29. The same 60 minutes billed as 99490 plus two units of 99439 pays $167.01. Complex CCM only overtakes the non-complex stack once the month runs past 60 minutes, because 99439 caps at two units while 99489 does not.
The other trap is a 45-minute month with genuinely high-complexity decision making. 99487 is not available, because the code needs 60 minutes. Report 99490 with one unit of 99439.
99491 and 99437: the practitioner's own clock
99491 and 99437 exist for the physician, nurse practitioner, physician assistant, or clinical nurse specialist who does the care management personally instead of directing staff. CMS is specific about the boundary: 99491 and 99437 count only time spent personally by the billing practitioner, and clinical staff time does not count toward the threshold.
The reverse is not symmetrical. Time the billing practitioner spends can count toward the 99490 and 99439 thresholds, as long as those minutes are not also used to report 99491.
You cannot report 99491 or 99437 in the same calendar month as 99487, 99489, 99490, or 99439. Pick a lane for the month.
What has to be in place before the first claim
CCM has a setup burden that catches practices out well after they have started tracking minutes. Every item below comes from MLN909188.
- An initiating visit for new patients, or any patient the practitioner has not seen in the previous year. It has to be a comprehensive face-to-face E/M visit, an Annual Wellness Visit, or an IPPE, and CCM has to actually be discussed during it. If CCM never came up, the visit does not count. The visit itself is billed separately. Where the practitioner does extensive assessment and care planning beyond the usual effort, HCPCS G0506 can be billed once alongside the initiating visit, worth about $66 in 2026.
- Consent, written or verbal, obtained once and documented. It has to tell the patient that the service is available, that cost sharing may apply, that only one practitioner can bill CCM in a calendar month, and that they can stop at any time effective at the end of the month.
- A certified EHR holding demographics, problems, medications, and medication allergies.
- An electronic comprehensive care plan built from a physical, mental, cognitive, psychosocial, functional, and environmental assessment. It has to be available promptly inside and outside the billing practice, and the patient or caregiver gets a copy.
- 24/7 access to a practitioner or clinical staff member for urgent needs, plus a designated care team member the patient can schedule routine appointments with.
One item is not a documentation requirement but sinks more programs than any of them: cost sharing applies to CCM. Patients who were never told about the coinsurance up front tend to disenroll the month the first statement arrives.
What you can and cannot bill in the same month
| Service | Same month as CCM? |
|---|---|
| TCM, 99495 and 99496 | Yes. CMS allows 99487, 99489, 99490, and 99491 for services provided during the 30-day TCM period |
| Complex and non-complex CCM together | No |
| 99491 or 99437 alongside 99490, 99439, 99487, or 99489 | No |
| APCM, G0556 through G0558 | No. APCM already bundles CCM, so pick one for the month |
| Home health supervision G0181, hospice supervision G0182 | No |
| Certain ESRD services, CPT 90951 through 90970 | No |
| Prolonged E/M services alongside complex CCM | No |
| Remote physiologic monitoring or remote therapeutic monitoring | One of the two, not both |
The TCM question, settled
Yes, you can bill TCM and CCM in the same month. CMS took that position in the CY2020 and CY2021 Physician Fee Schedule final rules, and MLN909188 states it plainly: CCM codes 99487, 99489, 99490, and 99491 may be reported for services provided during the 30-day TCM period. RHCs and FQHCs can bill both for the same patient during the same period too.
The condition is that no minute counts twice. Time supporting the TCM claim cannot also count toward a CCM threshold, and CMS says outright that you cannot count time toward the CCM service code for any other billed code. Guidance written before 2020 said the two services were mutually exclusive, and that language is still sitting in a lot of internal billing policies.
Where CCM programs lose money
Nothing below is ranked by frequency, because CMS does not publish a denial ranking for CCM. Each one is a rule that makes the month unbillable or the payment recoupable.
- Minutes counted toward CCM that were already used to support another billed code.
- Two practices working the same patient. Only one gets paid, and the second claim is a write-off of real staff time.
- No initiating visit for a patient the practice had not seen in more than a year, or an initiating visit where CCM was never mentioned.
- Consent obtained but not documented, or documented without the one-practitioner-per-month disclosure.
- 99487 billed for a month that never reached 60 minutes of clinical staff time.
- Three or more units of 99439 in one month.
- A care plan that lives as a PDF in one chart instead of an electronic record the rest of the care team can reach and update.
- Enrolled patients who quietly stop answering because nobody explained the coinsurance.
RHCs and FQHCs
Rural health clinics and federally qualified health centers used to roll all care coordination into a single code, G0511. That bundle is gone. The January 2026 RHC booklet and the March 2026 FQHC booklet both list the individual codes instead, so an RHC now reports 99490, 99491, and 99487 with 99439, 99437, and 99489 as add-ons, the same way a physician practice does. Payment is at the national non-facility Physician Fee Schedule rate, with the deductible and 20% coinsurance applied to the lesser of submitted charges or that rate.
How Pelica handles the CCM month
CCM fails on bookkeeping far more often than on care. The work happens across a nurse's inbox, a phone log, a care plan in the EHR, and a spreadsheet someone maintains for month-end billing. By the time anyone reconciles it, the month is closed and the answer to "did this patient hit 20 minutes" is a guess.
Pelica keeps the running total, the care plan, the consent record, and the initiating-visit date on one member record, and flags the patients sitting at 14 minutes on the 24th while there is still time to finish the work. The Care Management copilot works those queues directly and hands off to a coordinator when a person is genuinely needed. Customers run this across 350,000+ members, and go live in about two weeks.
Related terms
TCM CPT codes covers 99495 and 99496, the post-discharge service you can stack with CCM in the same month. APCM is the 2025 monthly bundle that replaces minute counting entirely and cannot share a month with CCM. The care management billing code reference puts the whole family on one page, and G0402 is one of the three visit types that can serve as a CCM initiating visit.
Sources
- CMS Medicare Learning Network: Chronic Care Management Services (MLN909188, June 2025)
- CMS: Care Management
- CMS: CY2026 Physician Fee Schedule Relative Value Files (January release)
- CMS: CY2026 Physician Fee Schedule Final Rule fact sheet (CMS-1832-F)
- CMS: Information for Rural Health Clinics (MLN006398, January 2026)