Ross Featured in National HCCA Article on Advanced Primary Care Management

Principal Martie Ross was featured in a recent issue of Report on Medicare Compliance, where she discusses advanced primary care management (APCM). The national publication is produced by the Health Care Compliance Association (HCCA) to provide updates on compliance strategies specifically pertaining to Medicare.

The article, “New APCM Codes Don’t Have a Time Minimum, but Avoid ‘Roster’ Billing,” written by Nina Youngstrom, features Ross’s comments during the Feb. 12 PYA webinar, “Providing and Billing Medicare for Care Management and Remote Monitoring Services.”

The Centers for Medicare & Medicaid Services created new reimbursement under the Medicare Physician Fee Schedule for APCM effective Jan. 1, 2025. Under this model, physicians bill for a monthly bundle on a per beneficiary basis, and the amount is based on the complexity of the beneficiary’s condition, not the time spent furnishing services to the beneficiary.

In the article, Ross explains CMS’ novel approach, “[APCM] is an attempt to take the value-based care model and put it in a fee-for-service world,” she says. Providers have three new codes, G0556, G0557, and G0558, for monthly billing based on patient complexity, not services provided.

She explains that providers must develop a plan of care and other requirements for each patient. CMS does not enforce a minimum monthly time requirement for billing, so “APCM becomes the floor for maintaining your care management program,” Ross says.

Roster billing is not allowed with APCM. With individualized plans of care, physicians must bill according to updates for each patient.

While providers cannot bill for multiple care management services if they opt for APCM, they can bill for both APCM and select other management services. Another benefit of APCM is that the model allows physicians to examine their entire patient base to identify gaps in care, Ross says.

Read the full article about advanced primary care management that ran on Feb. 17, 2025, on HCCA’s online platform, COSMOS, or access a PDF of the article.

Learn more:

Read more details about APCM in the PYA white paper, “Providing and Billing Medicare for Care Management Services.”

If you have questions about regulatory impacts or any other matter related to compliance or strategy and transactions, our executives are happy to help.

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