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Care management billing codes: TCM vs CCM vs PCM vs APCM vs CoCM vs RPM

~10 min readBy Pelica Health teamPublished August 28, 2026Updated August 28, 2026Reviewed by Catherine Zhao

Short answer

Medicare pays for care management through six code families, and the hard part is not the codes, it is which ones can share a calendar month. TCM covers the 30 days after a discharge. CCM and PCM are time-based monthly codes, two conditions versus one. APCM is a monthly bundle with no minute counting that absorbs CCM, PCM and TCM. CoCM and general BHI cover behavioral health. RPM covers device data. The table below gives each family's codes, population, time threshold, frequency, and what it stacks with.

Free to print or save as a PDF. No email, no sign-up. Codes and rules below reflect the 2026 Medicare physician fee schedule and current CMS guidance.

On a phone, swipe the tables sideways. They print in full.

The comparison table

Family	Codes	Who it is for	Time threshold	Frequency	Can it share a month?
TCM	`99495`, `99496`	A patient discharged from an inpatient, observation or partial hospitalization setting in the last 30 days	No minute threshold. Deadlines instead: interactive contact within 2 business days of discharge, and a face-to-face visit within 14 calendar days (99495, moderate MDM) or 7 calendar days (99496, high MDM)	Once per patient per 30-day TCM period. Only one physician or NPP may report it.	Yes with CCM, complex CCM and RPM. No inside a post-operative global surgery period for the same practitioner. No with APCM.
CCM	`99490` +`99439`; `99491` +`99437`	Two or more chronic conditions expected to last at least 12 months or until death, placing the patient at significant risk	20 minutes of clinical staff time (99490) or 30 minutes of practitioner time (99491) per calendar month. Add-ons cover each additional 20 or 30 minutes.	Monthly. Only one practitioner can bill CCM for a patient in a calendar month, and the consent has to say so.	Yes with TCM and RPM. No with complex CCM in the same month. No with APCM.
Complex CCM	`99487` +`99489`	The CCM population where the month also involves moderate or high complexity medical decision making	60 minutes of clinical staff time per calendar month, plus each additional 30 minutes	Monthly	Yes with TCM. No with non-complex CCM in the same month. No with prolonged E/M in the same month. No with APCM.
PCM	`99424` +`99425` (practitioner); `99426` +`99427` (clinical staff)	One single complex chronic condition expected to last at least 3 months. Often the specialist's code when primary care sits elsewhere.	30 minutes per calendar month minimum. CMS does not pay PCM under 30 minutes.	Monthly, with a new initiating visit required after one year to continue	No with APCM. Check CPT instructions before pairing PCM and CCM for the same patient in a month.
APCM	`G0556` (0–1 chronic condition), `G0557` (2+), `G0558` (2+ and a Qualified Medicare Beneficiary)	A practice that owns all of a patient's primary care and is the continuing focal point for their care	None. This is the only Medicare care management bundle with no monthly minute requirement.	Once per patient per calendar month. One practitioner only.	It already contains CCM, PCM, TCM, virtual check-ins, remote evaluation of pre-recorded information and interprofessional consultations, so none of those are billed separately that month. Behavioral health add-ons G0568, G0569 and G0570 are billable with it from January 1, 2026. RPM is not in the bundle.
CoCM and BHI	CoCM: `99492`, `99493`, +`99494`, `G2214`. General BHI: `99484`, `G0323`.	A behavioral health condition managed by the treating practitioner. CoCM adds a behavioral health care manager and a psychiatric consultant; general BHI does not require the consultant.	CoCM: 70 minutes of care manager time in the first month, 60 in each later month, +30 per add-on. G2214 covers 30 minutes. General BHI: at least 20 minutes per month.	Monthly	General BHI and CoCM cannot be reported in the same month for the same patient. With APCM, use G0568 or G0569 for CoCM and G0570 for general BHI instead.
RPM	Setup `99453`; device supply `99454` (16–30 days of data) or `99445` (2–15 days); management `99457` (first 20 min), `99470` (first 10 min), +`99458`	A patient using a device that transmits physiologic data	Device codes are day-count based, not time based. Management codes are time based and require at least one interactive communication with the patient or caregiver in the month.	Device supply per 30-day period; management per calendar month; setup once per episode	Yes with CCM and TCM, but CMS allows either RPM or RTM concurrently with a CCM or TCM service, not both. Time counted for RPM cannot also count toward CCM.

Start here

Work down the list. The first line that matches is usually your answer for that patient this month.

Was the patient discharged from a hospital, SNF, observation or partial hospitalization in the last 30 days? Bill TCM. Interactive contact within 2 business days, face-to-face within 14 days for 99495 or 7 days for 99496. TCM does not stop you from also billing CCM that month.
Does your practice own this patient's primary care, and do you want to stop counting minutes? Bill APCM. Pick the level by complexity: G0556 for 0 or 1 chronic condition, G0557 for two or more, G0558 for two or more when the patient is a Qualified Medicare Beneficiary. Then do not bill CCM, PCM or TCM for that patient that month.
Two or more chronic conditions, and you are still counting staff minutes? Bill CCM. 99490 for the first 20 minutes of clinical staff time, +99439 for each additional 20. Use 99491 and +99437 when the time is the practitioner's own. Use complex CCM (99487, +99489) when the month hit 60 minutes and involved moderate or high complexity decision making, and do not bill both in the same month.
One condition, not two? Bill PCM. 99424 and +99425 for practitioner time, 99426 and +99427 for clinical staff. Minimum 30 minutes in the month, and a new initiating visit after a year.
Behavioral health condition with a care manager? If a psychiatric consultant is on the case, bill CoCM (99492 in the first month, 99493 after, +99494 for each additional 30 minutes, or G2214 for a 30-minute month). Without a consultant, bill general BHI (99484). If the patient is already on APCM, use G0568, G0569 or G0570 instead.
Device sending physiologic data? Bill RPM. 99453 once for setup and education, then 99454 when the device transmitted 16 or more days in the 30-day period or 99445 when it transmitted 2 to 15 days, then 99457 or 99470 for management time with at least one interactive contact.
Still unsure whether two codes collide? Same patient, same calendar month, same practitioner, same work: pick one. Every concurrency rule below is a version of that sentence.

TCM: the 30-day clock

Transitional care management covers the 30-day period that begins the day the patient is discharged. Three things have to happen: interactive contact with the patient or caregiver within 2 business days, medically necessary non-face-to-face work during the period, and a face-to-face visit inside the window the code sets. Medication reconciliation has to be done on or before the date of that face-to-face visit.

Two rules cost practices money. First, if the face-to-face visit misses its window, you cannot bill TCM at all, and there is no partial credit. Second, if any part of the 30-day period falls inside a post-operative global surgery period for a procedure the same practitioner billed, Medicare does not pay TCM.

Two documented unsuccessful contact attempts do not sink the claim. CMS lets you report the service if you made two or more separate attempts in a timely manner, documented them, kept trying, and met the other requirements including the timely face-to-face visit.

CCM and complex CCM: counting minutes

Chronic care management needs two or more chronic conditions expected to last at least 12 months or until the patient's death, and a comprehensive care plan that is established, implemented, revised or monitored. The split people get wrong is whose minutes count. 99490, 99439, 99487 and 99489 count clinical staff time and can also include the billing practitioner's time if it is not being used to report 99491. 99491 and 99437 count only the billing practitioner's own time; clinical staff minutes do not help you reach that threshold.

An initiating visit is required before CCM starts for a new patient or one you have not seen in the previous year. It can be an E/M visit, an Annual Wellness Visit or an IPPE, and it is billed separately, but only if CCM was actually discussed during it.

Consent is a one-time step per practitioner, written or verbal, documented in the record, and it has to tell the patient that only one practitioner can bill CCM in a calendar month, that they can stop at any time, and that cost sharing may apply.

PCM: one condition, usually a specialist

Principal care management is CCM's single-condition sibling. The condition has to be expected to last at least three months and to put the patient at significant risk of hospitalization, acute exacerbation or decompensation, functional decline, or death. It is the natural code for a cardiology or nephrology practice managing one disease for a patient whose primary care sits somewhere else.

Two operational details: CMS does not pay PCM for less than 30 minutes in a calendar month, and after a year of PCM you need another initiating visit to keep going.

APCM: the bundle that ended minute counting

Advanced primary care management went live January 1, 2025 and changed the shape of the decision. Instead of documenting minutes against a threshold, a practice bills one monthly code and delivers a set of service elements when they are clinically appropriate. CMS describes the bundle as containing principal care management, transitional care management, chronic care management, virtual check-ins, remote evaluation of pre-recorded patient information, and interprofessional consultations.

The three levels track patient complexity rather than effort: G0556 for a patient with one chronic condition or none, G0557 for two or more, G0558 for two or more when the patient is a Qualified Medicare Beneficiary.

The requirement most practices underestimate is the last service element. To bill APCM you have to be measured on primary care quality, total cost of care and meaningful use of certified EHR technology, which means either reporting the Value in Primary Care MIPS Value Pathway or participating in a Shared Savings Program ACO, ACO REACH, Making Care Primary, or Primary Care First. That is a program commitment, not a billing configuration.

Two more details worth knowing. An initiating visit is not required if you or another provider in your practice saw the patient in the past three years or delivered APCM, CCM or PCM to them in the past year, and an Annual Wellness Visit can serve as the initiating visit when the same provider will deliver the APCM. And auxiliary personnel can furnish APCM incident to the billing provider's services under general supervision.

CoCM and BHI: the psychiatric consultant is the dividing line

The Psychiatric Collaborative Care Model needs three people: the treating practitioner who bills, a behavioral health care manager, and a psychiatric consultant. 99492 covers the first 70 minutes of care manager time in the first month, 99493 covers 60 minutes in each later month, +99494 covers each additional 30 minutes, and G2214 covers a month with 30 minutes of care manager time.

General BHI (99484, at least 20 minutes a month) is the version without a psychiatric consultant. G0323 is the parallel code when the time belongs to a clinical psychologist or clinical social worker. You cannot report general BHI and CoCM in the same month for the same patient.

New for January 1, 2026: three add-on codes let you deliver behavioral health alongside APCM. G0568 and G0569 cover CoCM for a patient also receiving APCM, and G0570 covers general BHI. They are not time based, and you have to bill an APCM base code in the same month to use them.

RPM: 2026 lowered both floors

Remote physiologic monitoring splits into device codes and management codes. 99453 pays once for setup and patient education. 99454 pays for the device and transmissions when the patient recorded 16 or more days of data in a 30-day period. Management is 99457 for the first 20 minutes of clinical time in a calendar month, with +99458 for each additional 20, and it requires at least one interactive, two-way communication with the patient or caregiver.

The 2026 fee schedule added two codes that lower the entry thresholds. 99445 covers a 30-day period with 2 to 15 days of transmitted data, which is the answer to the old complaint that a patient who monitored for 12 days produced nothing billable. 99470 covers the first 10 minutes of management time. Both appear on the 2026 relative value file alongside the original four.

The stacking rules in one place

TCM and CCM in the same month: allowed. CMS names 99487, 99489, 99490 and 99491 as reportable for services provided during the 30-day TCM period, as long as the same time and effort are not counted twice. This changed in 2020, which is why older guidance says the opposite.
Complex and non-complex CCM in the same month: not allowed. Do not report 99491 or 99437 in the same calendar month as 99487, 99489, 99490 or 99439.
APCM with CCM, PCM or TCM: not allowed for the same patient in the same month, because APCM already contains them.
APCM with behavioral health: allowed through the add-ons. G0568, G0569 and G0570 exist specifically for this, and require an APCM base code in the same month.
CoCM and general BHI in the same month: not allowed for the same patient.
RPM or RTM with CCM or TCM: one, not both. CMS allows either remote physiologic monitoring or remote therapeutic monitoring concurrently with a CCM or TCM service.
CCM with home health supervision, hospice supervision or certain ESRD services: not allowed. That means G0181, G0182 and CPT 90951 through 90970.
Complex CCM and prolonged E/M in the same month: not allowed.
Time never counts twice. Minutes reported under one care management code cannot be counted toward another.

Two things that changed recently

G0511 is gone. Rural health clinics and federally qualified health centers used to roll CCM and behavioral health integration into one general care management code. CMS finalized the move to individual code billing in the CY2025 physician fee schedule, and G0511 does not appear on the 2026 relative value file. RHCs and FQHCs now bill the underlying CCM, PCM, BHI, APCM and RPM codes directly.

2026 has two conversion factors. The January 2026 relative value files carry $33.5675 for qualifying APM participants and $33.4009 for everyone else. Multiply a code's total non-facility RVU by the conversion factor that applies to your practice, then adjust for your locality's GPCIs, and check the CMS physician fee schedule look-up tool before you build a revenue model on a national average.

Where the money actually leaks

None of these codes fails because a biller picked the wrong number. They fail because the discharge notification arrived three days late, because nobody called inside the two business days, because the 30-day face-to-face slipped to day 16, or because the care plan lived in a note nobody could find at audit. The code is the easy part.

Pelica's Care Management copilot runs on one live member record built from claims, EHR, pharmacy, lab and ADT feeds. It sees the discharge when the ADT lands, builds the follow-up worklist, and tracks the clock on each patient until the work is done and documented. At HealthCare Partners, the largest IPA in the country, that closes more than 70% of transitions of care gaps within 30 days, with 100% team adoption across 200,000+ patients managed live.

Sources

Frequently asked questions

Common questions about Medicare care management codes and concurrent billing.

Can you bill TCM and CCM in the same month?

Yes. CMS allows chronic care management to be reported for services provided during the 30-day transitional care management service period, as long as the work is medically reasonable and necessary and the same time and effort are not counted twice. The CMS chronic care management booklet names 99487, 99489, 99490 and 99491 as billable during the TCM period, and the transitional care management booklet lists CCM among the codes you can bill concurrently with TCM. This has been allowed since 2020; the original 2015 CCM rules prohibited it, which is why the older guidance still circulates.

Can APCM and CCM be billed in the same month?

No, not by the same practitioner for the same patient. CMS built advanced primary care management as a bundle that already contains chronic care management, principal care management, transitional care management, virtual check-ins, remote evaluation of pre-recorded patient information, and interprofessional consultations. In a month you bill G0556, G0557 or G0558, you do not separately bill those services. Only one practitioner can furnish and be paid for APCM in a calendar month, and the patient consent has to say so.

What is the time threshold for APCM?

There is not one. APCM is the only Medicare care management bundle with no monthly minute requirement. You bill it once per patient per calendar month when you meet the service elements, which include patient consent, an initiating visit for new patients, 24/7 access, an electronic care plan, care transition coordination, population-level management, and performance measurement. That last element means reporting the Value in Primary Care MIPS Value Pathway or participating in a Shared Savings Program ACO, ACO REACH, Making Care Primary, or Primary Care First.

What replaced G0511 for RHCs and FQHCs?

The individual care management codes. G0511 was the single general care management code rural health clinics and federally qualified health centers used for CCM and behavioral health integration. It is no longer on the 2026 physician fee schedule relative value file. RHCs and FQHCs now bill the underlying CCM, PCM, BHI, APCM and RPM codes directly, which pays differently by service instead of one flat monthly amount.

What is the difference between CCM and PCM?

The number of conditions. Chronic care management requires two or more chronic conditions expected to last at least 12 months or until the patient's death. Principal care management covers a single complex chronic condition expected to last at least three months. PCM is the code a specialist typically uses when managing one disease for a patient whose primary care sits elsewhere, and CMS requires a new initiating visit after one year to continue PCM.

Which care management codes can be billed with remote patient monitoring?

RPM can be billed alongside CCM and TCM, with one limit: CMS allows either remote physiologic monitoring or remote therapeutic monitoring concurrently with a CCM or TCM service, not both. Time counted toward an RPM management code cannot also be counted toward the CCM time threshold. Remote monitoring is not one of the services CMS folded into the APCM bundle, so it stays separately billable.

Picking the code is easy. Hitting the 2-day and 30-day clocks is not.

Pelica's Care Management copilot sees the discharge when the ADT lands, builds the follow-up worklist, and tracks each patient's clock until the work is done and documented. The largest IPA in the country closes more than 70% of transitions of care gaps within 30 days.

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