FQHC APCM Compliance & Audit Readiness Checklist

Confirm that APCM billing does not overlap with face-to-face encounters billed under the PPS rate to avoid double-billing audits.

Document at least 20 minutes of non-face-to-face care coordination per month with time-stamped EHR entries.

Maintain a comprehensive care plan for at least two chronic conditions that is accessible to the entire FQHC care team.

Store verifiable patient consent for APCM services, ensuring patients are informed of potential cost-sharing responsibilities.

Document that all APCM services performed by clinical staff are under the general supervision of an FQHC practitioner.

Perform and document monthly medication reconciliation for all patients enrolled in the APCM program.

Map APCM outreach activities to specific Uniform Data System (UDS) quality measures for streamlined annual reporting.

Ensure that any coinsurance for APCM services is adjusted according to the FQHC's sliding fee scale policy.

Incorporate Social Determinants of Health (SDOH) screenings into the monthly APCM check-in workflow.

Document referrals to community-based organizations as part of the care coordination documentation for HRSA audits.

Review APCM outcomes monthly during Quality Improvement (QI) committee meetings to meet Section 330 requirements.

Verify that all APCM communication materials are available in the primary languages of the FQHC's patient population.

Use AI call handling to provide 24/7 patient access to care coordination, a key requirement for APCM compliance.

Deploy automated AI voice outreach in multiple languages to engage diverse chronic disease populations effectively.

Ensure AI-driven call logs and patient responses are automatically pushed to the EHR to create a seamless audit trail.

Set up AI triggers for immediate outreach following hospital discharge or ED visits to satisfy care transition rules.

Configure AI to identify and flag transportation or food insecurity barriers during routine automated check-ins.

Audit the AI platform for end-to-end encryption and HIPAA-compliant data storage of all patient interactions.

Properly allocate APCM staff time and AI software costs on the Medicare Cost Report to avoid reimbursement errors.

Verify that APCM revenue is correctly excluded from the calculation of the PPS wrap-around payment where applicable.

Run monthly reports to ensure no patients are simultaneously enrolled in APCM and CCM or TCM programs.

Maintain logs distinguishing time spent on APCM versus general FQHC administrative duties for cost-based reimbursement.

Monitor APCM enrollment impact on overall provider productivity and FQHC encounter volume.

Conduct quarterly internal audits of APCM claims to identify and correct billing errors before CMS audits occur.