APCM Compliance Checklist for Family Medicine Practices

Analyze EHR data to identify patients with two or more chronic conditions who meet the APCM risk-stratification criteria.

Secure verbal or written consent for APCM services, ensuring the patient understands cost-sharing and 24/7 access benefits.

Ensure patients previously enrolled in legacy Chronic Care Management are formally transitioned to the APCM model without billing overlaps.

Conduct annual SDOH screenings to identify barriers to care, a core requirement for comprehensive family medicine management.

Confirm preferred communication channels for monthly AI-driven outreach calls and care coordination reminders.

Ensure every APCM patient has a digitized, shareable care plan that addresses physical, mental, and social health needs.

Implement AI call routing or after-hours triage to ensure patients can reach a clinician for urgent needs at any time.

Use AI call logs and transcripts to prove monthly non-face-to-face interactions regarding chronic condition management.

Document reconciliation of all medications for patients transitioning between care settings or family households.

Link APCM outreach to preventive screenings, ensuring the whole-family health management model is maintained.

Utilize appropriate G-codes for APCM, ensuring they are not billed alongside conflicting CCM or PCM codes in the same month.

Maintain a secure, HIPAA-compliant repository of all automated patient outreach for audit verification purposes.

Review a random sample of 10% of APCM enrollees to ensure the 13 service elements are documented in the EHR.

Track how APCM data contributes to Value-Based Care metrics and the MIPS Promoting Interoperability category.

Ensure the EHR reflects that all care management activities, including AI-facilitated tasks, are under physician supervision.