APCM Compliance Checklist for Allergy & Immunology

Confirm the patient has at least one complex chronic condition (PCM) or two or more (CCM) such as persistent asthma or chronic urticaria.

Obtain and record verbal or written consent for APCM services in the EMR, explaining cost-sharing responsibilities.

Ensure the patient has been seen by the allergist or immunologist for a face-to-face visit within the last 12 months.

Flag patients on biologics like Xolair or Nucala who require intensive monitoring and qualifying for higher-level care management.

Identify maintenance-phase immunotherapy patients who require long-term structured follow-up for compliance and safety.

Maintain a current, digital Asthma Action Plan (AAP) for all respiratory patients, accessible by the entire care team.

Document current epinephrine auto-injector prescriptions and confirm the patient knows how to use the device.

Review and update all allergy medications including inhalers, nasal sprays, and antihistamines at every touchpoint.

Document specific environmental triggers and avoidance strategies discussed during monthly care management calls.

Outline the schedule for monitoring peak flow, symptom scores, and potential side effects for patients on specialty injectables.

Ensure protocols for anaphylaxis and food allergy emergencies are clearly defined in the care management record.

Utilize AI call handling to automatically log the duration and content of every patient interaction regarding care management.

Record time spent by clinical staff or automated assistants reviewing inhaler or biologic injection techniques.

Log all check-ins for immunotherapy patients to track local or systemic reactions between office visits.

Ensure all calls regarding IgG levels or skin test results are logged toward the monthly 20-minute billing threshold.

Use AI software to aggregate all clinical staff time spent on a patient each month to ensure CPT 99424/99490 requirements are met.

Verify that CPT codes 99424-99427 (PCM) or 99490 (CCM) match the documented communication logs in the EMR.

Ensure APCM is only billed once per calendar month and does not overlap with other time-based management codes.

Maintain a secure, HIPAA-compliant digital trail of all AI-generated call transcripts for at least six years.

Confirm that all care management activities performed by staff or AI are under the general supervision of the allergist.

Perform regular internal reviews of care plans to ensure they align with the latest AAAAI practice parameters.