SUD APCM Compliance & Audit Readiness Checklist

Ensure specific consent is obtained for all APCM-enrolled patients before sharing any SUD-related treatment data.

Ensure all AI-generated reports and patient records include the required federal notice prohibiting further disclosure.

Use AI call handling to record and timestamp verbal consents for record sharing and care coordination.

Create a workflow for the immediate cessation of data sharing if a patient revokes consent for SUD services.

Audit electronic health records to ensure SUD-specific clinical notes are stored separately from general medical data.

Document at least 20 minutes of qualifying staff time per month for G0568 billing, including AI-assisted outreach.

Maintain logs of PHQ-9, GAD-7, and AUDIT-C screenings performed as part of the APCM SUD care plan.

Provide evidence of monthly check-ins regarding buprenorphine or naltrexone adherence and side effect management.

Document all outreach attempts within 72 hours of a patient's discharge from an inpatient detox or residential program.

Ensure all billed APCM activities are directly linked to the patient's primary SUD diagnosis and recovery goals.

Use AI voice agents to conduct weekly structured check-ins to identify early warning signs of relapse.

Use AI to confirm high-risk OUD patients have access to naloxone and have received overdose education.

Configure AI call scripts to flag keywords like 'craving' or 'withdrawal' for immediate clinical escalation.

Reduce treatment gaps by automating reminders for buprenorphine refill appointments and pharmacy pickups.

Ensure every automated interaction is transcribed and uploaded to the patient chart to serve as an audit trail.

Update the comprehensive care plan every 12 months, specifically addressing SUD and co-occurring conditions.

Provide evidence that APCM patients have 24/7 access to a care navigator or clinical staff via phone or portal.

Document coordination for social determinants of health, such as housing or transportation for MAT clinic visits.

Document a review of all medications, checking for potential interactions with MAT pharmacotherapy.

Log all communications with external therapists, recovery coaches, or intensive outpatient programs (IOP).