TCM Frequency

Nicoletti Notes February 2026
Published February 10th, 2026

Transitional Care Management (99495, 99496)

Family practice and internal medicine providers continue to ramp up their use of transitional care management (TCM) services. As background, the TCM services comprise two codes – the “at least moderate” level of medical decision-making (MDM) code 99495 and the “high MDM” code 99496.

Note the full descriptors:

• 99495: Transitional care management services with the following required elements: Communication (direct contact, telephone, electronic) with the patient and/or caregiver within 2 business days of discharge; At least moderate level of medical decision making during the service period; Face-to-face visit, within 14 calendar days of discharge
• 99496: Transitional care management services with the following required elements: Communication (direct contact, telephone, electronic) with the patient and/or caregiver within 2 business days of discharge; High level of medical decision making during the service period; Face-to-face visit, within 7 calendar days of discharge

Both codes show strong growth. But the go-to code choice, based on MDM, differs by specialty, according to Medicare claims data. The two tables below detail the total claims, payments and denial rates for “moderate MDM” 99495 and “high MDM” 99496 for family practice and internal medicine specialties, respectively. The tables show claims data for the three-year period from 2022-2024.

In the most recent year, family practice providers reported moderate MDM code 99495 about 56% of the time and high MDM code 99496 about 44% of the time. For internal medicine, however, high MDM code 99496 came out on top, making up 51% of their total TCM claims. The code selection (while always based on medical necessity) can make a difference in payments. Code 99495 has a non-facility rate of $201.20, while 99496 pays a non-facility fee of $272.68, according to the Medicare physician fee schedule look-up tool.

It’s worth noting that, as claims are rising, so are denial rates, which spiked for both specialties and for both levels of MDM in 2024. Both family practice and internal medicine saw the highest denial rates for 99496 (4.9% and 5.4%, respectively), which came in 2024.

Check the Requirements for High MDM 99496

As the code descriptor shows, providers must meet strict requirements in order to accurately bill 99496. Specifically, providers must meet timing requirements for outreach and a face-to-face visit in addition to meeting the threshold of high MDM:

• Establish direct communication with the patient or caregiver within 2 business days of discharge. In its coding guidelines, the AMA stipulates that the discharge may come from “an inpatient hospital setting … partial hospital, observation status in a hospital, or skilled nursing facility/nursing facility.” The AMA also notes that the contact may be face-to-face, by telephone or through electronic means. CMS further adds that providers can still report the service “if you make 2 or more unsuccessful contact attempts in a timely manner.”
• Ensure the patient is returning to a “community setting,” which can include home, nursing facility, assisted living facility.
• Perform a face-to-face visit within 7 calendar days of discharge.
• Perform medication reconciliation and management no later than the date of the face-to-face visit.
• Meet the requirements for high MDM, which is defined within the E/M Services Guidelines. For 99496 like other E/M codes, providers must successfully meet two of the three elements of MDM. As a reminder, the three elements of MDM are:
  • Number and complexity of problems addressed at the encounter.
  • Amount and/or complexity of data to be reviewed and analyzed.
  • Risk of complications and/or morbidity or mortality of patient management.

Who Can Bill?

Physicians and non-physician practitioners (NPP) can report the face-to-face portion of the TCM encounter, and they also can supervise auxiliary personnel. For the non-face-to-face portion, NPPs as well as auxiliary personnel are eligible to report the service under incident to rules.

What to Document

CMS says that, at a minimum, providers should document: the patient’s discharge date; the date of the first interactive contact with the patient or caregiver (or the dates of attempted contact); the date of the face-to-face visit; and the degree of MDM.