CCM billing guide for 2026.

What changed for care management in 2026

• Higher conversion factor. The CY 2026 final rule set two conversion factors: $33.4009 for most practitioners and $33.5675 for qualifying APM participants. CMS describes these as increases of 3.26% and 3.77% over 2025.
• No efficiency cut for care management. The rule's new -2.5% efficiency adjustment applies to non-time-based codes only. CMS lists care management and behavioral health services among the codes it does not apply to.
• CCM and PCM rules did not change. The 2026 rate increase for these codes comes from the conversion factor and practice expense values, not from new billing policy.
• APCM behavioral health add-ons. G0568, G0569 and G0570 let the practitioner billing APCM add collaborative care or behavioral health integration without counting minutes. See the APCM guide.
• New remote monitoring codes. CPT added 99445 (RPM with fewer than 16 days of data in a 30-day period) and 99470 (RPM management with less than 20 minutes of interaction in a month), with parallel RTM codes.
• FQHCs and RHCs. G0511, G0512 and G0071 ended on January 1, 2026. Clinics now bill the individual care management codes and are paid at the national non-facility rate.

Care management codes and rates, 2025 vs 2026

How CCM time is counted

• The service period is one calendar month. Minutes do not carry over.
• 99490 and 99491 can be billed as soon as the time threshold is met; you do not need to hold the claim until month end. Complex CCM is billed at the end of the month.
• Only time spent by clinical staff who meet the incident-to rules counts toward 99490, 99439, 99487 and 99489. Other staff can help, but their time does not count.
• Billing practitioner time can count toward 99490 and 99439, as long as it is not also used to bill 99491. Codes 99491 and 99437 count only the practitioner's own time.
• When one activity serves several patients, the time is split among them. Time and effort cannot be counted twice, or toward any other billed code.

What cannot be billed in the same month

• Non-complex and complex CCM together: 99491 and 99437 cannot go with 99487, 99489, 99490 or 99439.
• CCM and PCM by the same practitioner for the same patient. A primary care practitioner billing CCM and a specialist billing PCM for a different condition is allowed.
• CCM, PCM or TCM by the practitioner who bills APCM for that patient.
• CCM with home health or hospice care plan oversight (G0181, G0182) or ESRD monthly services (90951 to 90970).
• Complex CCM with prolonged E/M services.
• Both RPM and RTM alongside CCM; one or the other can be billed concurrently.

Transitional care management can be billed in the same month as CCM.

Documentation checklist

• The initiating visit (E/M levels 2 to 5, AWV or IPPE) if the patient is new or not seen in the past year, and that CCM was discussed.
• Written or verbal consent, with the required disclosures, recorded in the chart.
• Demographics, problems, medications and allergies in certified EHR technology.
• The electronic comprehensive care plan, and that a copy was given to the patient.
• A time log for each time-based code: who, when, how long, and what was done.
• For APCM, no time log, but the service elements provided that month should be documented.

Common CCM billing errors

A 2021 HHS Office of Inspector General audit of 2017 and 2018 claims found $1.9 million in Medicare overpayments across 50,192 CCM claims. The two largest causes were:

• CCM billed more than once for the same patient in the same service period: $1.43 million across 38,447 claims.
• CCM billed together with overlapping care management services: $438,262 across 10,882 claims.

CMS guidance names three more mistakes that make a claim unbillable:

• Billing without documented consent. CMS says the practitioner then cannot bill Medicare or the patient.
• Billing for CCM furnished by people located outside the United States.
• Billing CCM provided by a third party with little oversight from, or clinical integration with, the billing practitioner.

How practices avoid them

Most of these errors come from tracking: who already billed this month, which codes overlap, whether consent is on file. A monthly worklist that checks those before a claim goes out removes most of the risk. Vybz AI care teams prepare that worklist and run patient outreach, while your clinical staff do and log the billable time.