APCM Compliance & Audit Checklist: Multiple Chronic Conditions

Ensure patient records document at least three chronic conditions expected to last 12 months or until death to justify G0558 billing.

Obtain and record verbal or written consent for APCM services, explicitly explaining cost-sharing and 24/7 access to the care team.

Apply a standardized risk stratification tool to identify patients qualifying for high-complexity G0558 billing versus G0557.

Develop a patient-centered care plan addressing physical, mental, and psychosocial needs across all documented conditions.

Screen for SDOH factors that complicate the management of multiple chronic conditions and document these barriers in the EHR.

Implement AI-powered call routing or after-hours services to ensure patients have continuous access to a qualified clinician.

Maintain records of all communications with external specialists to prevent fragmented care and conflicting treatment guidelines.

Document follow-up within 2 business days of discharge from a hospital or SNF to reduce high readmission risks for multi-morbid patients.

Record instances where patients or caregivers were involved in choosing treatment paths for competing chronic conditions.

Log referrals to community-based services that support chronic condition management, such as medical transport or nutrition programs.

Perform a comprehensive review of all prescriptions, OTCs, and supplements at every APCM encounter to prevent adverse events.

Check for contraindications between medications prescribed for different chronic conditions by various specialists.

Use automated AI call tools to check in on patient adherence and identify barriers like cost, side effects, or confusion.

Periodically assess the necessity of each medication to reduce the burden of polypharmacy in multi-morbid patients.

Sync with multiple pharmacies to ensure patients receive all medications and understand complex dosing schedules.

Use automated logs to track clinical staff time spent on coordination, even if not directly interacting with the patient.

Ensure the correct code is used based on the exact number of conditions and the intensity of care coordination provided.

Verify that the comprehensive care plan is electronically accessible to all providers within the practice 24/7.

Ensure the APCM care plan is updated following the patient's most recent AWV or comprehensive physical exam.

Conduct monthly internal audits of 10% of APCM charts to ensure all CMS documentation requirements are consistently met.