Question 1

Who is the primary billing entity for APCM in a solo practice?

Accepted Answer

In a solo practice, the physician is the primary billing entity. For APCM services, the billing must be submitted under the solo provider's NPI. Unlike large groups with multiple mid-levels, the solo doctor remains personally responsible for the clinical oversight and final attestation of the care management services provided.

Question 2

What are the incident-to billing rules for solo doctors?

Accepted Answer

APCM services are typically billed 'incident-to' the solo physician. This requires that the physician provides direct supervision, though for care management, this often means being available via telecommunication rather than physical presence in the same room. Our AI system ensures all delegated tasks are tracked to meet these specific Medicare requirements.

Question 3

How does a solo practice meet the Medicare initiation visit requirement?

Accepted Answer

Before APCM billing begins, a solo doctor must conduct an initiating visit for new patients or those not seen within a year. This is typically done during an Annual Wellness Visit (AWV) or a comprehensive E/M visit. Once this visit is documented in your EHR, the turnkey APCM program can begin the monthly care management cycle.

Question 4

Can a solo practitioner outsource APCM without violating compliance?

Accepted Answer

Yes, CMS allows solo practitioners to utilize third-party clinical staff and technology. The key is that the solo doctor must maintain oversight and the care must be integrated into the practice's EHR. Our AI-powered solution acts as your virtual care team, documenting every interaction to ensure you meet the 'incident-to' criteria.

Question 5

What documentation is required for the monthly 20-minute threshold?

Accepted Answer

To bill for APCM, you must document at least 20 minutes of non-face-to-face care management per month. This includes phone calls, care plan revisions, and coordination with specialists. Our AI call center automatically logs the duration and clinical content of every patient interaction, ensuring you never miss a billable minute.

Question 6

How do I document AI-assisted patient interactions for audits?

Accepted Answer

For audit protection, every AI-assisted interaction must generate a timestamped, clinical note that is pushed to the patient's chart. Our system creates detailed summaries of patient check-ins and medication adherence updates, providing a clear audit trail that proves the medical necessity and time spent on care coordination.

Question 7

Must APCM documentation be stored directly in my EHR?

Accepted Answer

Yes. To remain compliant, all care management activities must be part of the patient's permanent electronic health record. Our turnkey solution integrates with common solo practice EHRs to automatically upload encounter notes, ensuring your documentation is centralized and accessible for any future CMS reviews.

Question 8

How do we track non-face-to-face time for solo practices?

Accepted Answer

Tracking time manually is the biggest hurdle for solo doctors. Our platform uses automated digital timers for every patient interaction, from phone triage to care plan updates. This data is aggregated monthly, allowing the solo doctor to review and approve the total time spent before submitting claims.

Question 9

How can a solo doctor manage APCM without hiring new staff?

Accepted Answer

By using AI-powered call handling, the solo doctor delegates the routine tasks of care management—such as monthly check-ins and symptom tracking—to an automated system. This removes the need to hire a $50k/year care coordinator, allowing the solo practice to retain more of the $150k+ in potential annual APCM revenue.

Question 10

Does AI call handling count toward the 20-minute requirement?

Accepted Answer

Yes, provided the AI operates under the physician's established protocols and the data is reviewed by clinical staff or the provider. Medicare recognizes the use of technology to facilitate care management, as long as it supports the provider's ability to manage the patient's chronic conditions effectively.

Question 11

How much time must the solo physician personally spend on APCM?

Accepted Answer

The goal of a turnkey AI solution is to limit the physician's time to 'exception-based' care. You should spend roughly 2-3 minutes per patient per month reviewing the aggregated care logs and signing off on the monthly billing, while the AI handles the hours of patient outreach and data collection.

Question 12

Can AI handle the initial patient consent process?

Accepted Answer

AI can facilitate the consent process by explaining the program benefits and costs to the patient. However, the solo practice must ensure that the patient's verbal or written consent is documented in the EHR. Our system captures this consent during the initial outreach call and stores it for compliance purposes.

Solo Practice APCM Compliance & Documentation Guide

Regulatory & Billing Requirements

Documentation & Record Keeping

AI Workflow & Delegation

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