APCM Billing Code Setup Checklist for CMS Compliance

Ensure your EHR and billing software are updated with the 2025 APCM codes for basic, intermediate, and advanced levels.

Link AI-generated call summaries and timestamps to patient records to provide evidence of care coordination activity.

Confirm that the billing provider's taxonomy code is recognized by CMS as an eligible primary care specialty for APCM.

Implement rules to prevent billing APCM alongside CCM or PCM codes, which triggers OIG double-dipping audits.

Set the default POS to 11 (Office) or the appropriate facility code to align with the primary care setting requirements.

Create EHR templates that mandate documentation for all required elements, including 24/7 access and SDOH assessments.

Use AI call handling to automatically document after-hours patient interactions, ensuring a record of continuous access.

Document the patient's verbal or written consent for APCM services, including notification of cost-sharing responsibilities.

Ensure the comprehensive care plan is updated monthly and shared electronically with the patient via secure portal or AI-delivery.

For higher-level codes (G0517/G0518), ensure documentation reflects interventions related to social determinants of health.

Configure digital storage to retain all APCM-related documentation, including AI call transcripts, for the CMS-mandated 7 years.

Review a random 5% sample of APCM claims against the 13-element checklist before final submission each month.

Conduct quarterly training for billing and clinical staff to prevent knowledge loss during turnover and ensure consistent coding.

Use AI analytics to track the frequency and quality of patient touchpoints to prove a 'continuous relationship' exists.

Ensure non-face-to-face time spent on referrals and pharmacy coordination is captured in the compliance audit trail.