Question: Can we bill Advanced Primary Care Management every month for a patient we sign up, even if we don’t provide any services during that month?

Answer: In my opinion, no. Although other consultants have other opinions and believe they are per member/per month codes.

The CMS website doesn’t address this directly in the article here.

Quotes in italics are from the 2025 and 2026 Final Rules.

“After consideration of public comments, we are finalizing our proposal without modification to establish APCM codes and descriptors that reflect all elements of service furnished during a month without specifying the amount of time that must be spent furnishing the services during the month, and without including time-related billing restrictions for the elements of the services.”

• This seems to imply that something has to be done during that month.

“Therefore, we anticipate that all the APCM scope of service elements (for example, comprehensive care management and care coordination) will be routinely provided, as deemed appropriate for each patient, acknowledging that not all elements may be necessary for every patient during each month (for example, the beneficiary may have no hospital admissions that month, so there is no management of a care transition after hospital discharge). We also anticipate that there may be some months where it may be appropriate for some service elements to be performed more than once for the patient.”

“Comment: Other commenters recommended we use the CMS Innovation Center model, per beneficiary per month (PBPM) payments, and conduct greater research to determine more appropriate payment rates. Commenters also discussed valuation in the context of concurrent billing restrictions, with some commenters citing the inclusion of CTBS and interprofessional consultation services for which payment rates are in some cases higher than the monthly rate for APCM.

Response: We continue to believe that the most accurate mechanism for determining the appropriate work RVU for this service is to refer to values established for existing CPT codes. We note further that using CCM codes as a reference to value the APCM codes would have the benefit of assuring appropriate relativity with similar services.”

In this comment, CMS notes that commenters think the per member/per month benefit would be a better model, and CMS believes that the care management codes are the reference point for RVUs.

The 2026 Final Rule discusses add-on Behavioral Health Integration codes that are used only with APCM. I sent this after a care management webinar in response to a question about it. You can review it here.

Here is a comment and CMS’s response from page 427 of the display copy of the rule. In my opinion, it supports documenting services performed in a calendar month when billing APCM and BHI services.

“Comment: A commenter stated that continuing to document the behavioral health services delivered and patient interactions associated with billing the add-on codes was unnecessarily burdensome and recommended that we allow practitioners to attest that they have the ability to provide integrated behavioral health services without documenting each required element of the service.

Response: We appreciate the commenter for the feedback and acknowledge that some administrative burden remains to bill the proposed add-on codes. However, at this time, we continue to believe that it is important that the elements of the particular add-on service are documented in the medical record, though we may consider this comment in future rulemaking.”

My advice: if you don’t perform any of the services in the list, don’t report APCM.