Understanding the New Advanced Primary Care Management Services

The Centers for Medicare & Medicaid Services (CMS) recently introduced new Advanced Primary Care Management Services (APCM) in the 2025 Medicare Physician Fee Schedule (PFS). These services are designed to make primary care more accessible, coordinated, and patient focused. By emphasizing personalized care, prevention, and chronic disease management, APCM reduces the administrative burden of time-based billing while improving health outcomes. Below, we will review the new APCM codes, what is included with these services, and their billing requirements.

What are Advanced Primary Care Management Services?

APCM combines elements of existing care programs such as chronic care management (CCM), principal care management (PCM) and communications technology-based services, into a single monthly billing option. This change prioritizes quality and frequency of patient-physician interactions whether at home, in the office, or through telehealth over traditional time-based billing requirements.

Key features include:

• Flexible care delivery options, such as telehealth and remote monitoring, ideal for patients facing transportation or mobility challenges.
• Streamlined billing processes, allowing providers to focus more on delivering patient care rather than meeting time thresholds.

What are the APCM Codes?

The new APCM codes have the same basic requirements for practitioners; services may be provided by clinical staff and must be directed by a physician or other healthcare professional who is responsible for all primary care and serves as the ongoing central point for all necessary healthcare services, per calendar month. However, the codes vary based on patient complexity:

• G0556 (Level 1): For patients with one chronic condition
• G0557 (Level 2): For patients with two or more chronic conditions
• G0558 (Level 3): For patients who are a Qualified Medicare Beneficiary (QMB) with two or more chronic conditions

Billing Requirements for APCM

Practices must be equipped to provide all 13 APCM service elements, but they are not required to deliver every element each month. This flexibility allows practices to customize services based on patient needs rather than the time spent providing care management.

Unlike CCM and PCM services, APCM codes are not time-based. As a result, care management services that don’t meet the 20- or 30-minute thresholds for CCM and PCM can still be billed under APCM.

However, CMS clarified that APCM services should not be billed concurrently with CCM, PCM or TCM services. Remote physiologic monitoring and remote therapeutic monitoring (RTPM) services are separately billable.

The 13 service elements are summarized below:

• Obtain patient consent
• Conduct an initiating visit for patients not seen within 3 years
• Provide 24/7 access to care team for urgent needs
• Maintain a designated contact for continuity of care
• Offer alternative options for care delivery
• Perform comprehensive care management, including assessments, preventive services, and medication management
• Develop a patient-centered comprehensive care plan (electronic care plan accessible to patients and providers)
• Manage and coordinate care transitions (ensuring timely exchange of electronic health information and patient follow-up after emergency room visits and hospital discharges)
• Facilitate ongoing communication and coordination with community-based service providers
• Use asynchronous non-face-to-face digital communication methods
• Conduct patient population analysis
• Perform risk stratification
• Measure performance and ensure the meaningful use of Certified Electronic Health Record Technology (CEHRT)

Benefits of APCM for Patients and Providers

For Patients:

• Increased access to care through telehealth and remote monitoring
• Enhanced coordination and continuity of care
• Proactive management of chronic conditions, leading to better outcomes

For Providers:

• Reduced administrative burden through simplified billing
• Greater flexibility in delivering care that meets patients’ unique needs
• Improved efficiency in managing complex patient populations

Looking Ahead

The implementation of APCM reflects a shift toward making primary care more flexible, accessible and outcomes focused. By encouraging virtual care and removing time-based requirements, CMS is moving toward a model that could redefine how primary care is delivered across the nation’s healthcare system. As these codes are rolled out, their effectiveness will likely be evaluated based on their impact on patient outcomes, healthcare costs, and provider satisfaction, which may influence further policy development.