OnCare360
Aug 11, 2025
Chronic Care Management (CCM) is often provided alongside other reimbursable care coordination services such as Remote Patient Monitoring (RPM), Principal Care Management (PCM), Transitional Care Management (TCM), and Behavioral Health Integration (BHI). Billing these services concurrently can improve patient care and revenue, but requires careful documentation, time segmentation, and compliance with CMS rules.
This guide outlines the rules, opportunities, and safeguards for billing CCM in combination with other chronic care programs.
Executive Summary
CCM can be billed concurrently with several care management services when requirements for each are met and documentation is distinct.
Key to compliance: separate time tracking, clear role delineation, and service scope differentiation.
A workflow-integrated approach prevents denials and sustains program efficiency.
Table of Contents
CCM Overview in the Billing Context
Common Concurrent Billing Combinations
CMS Guidelines: Permissible Combinations and Restrictions
Time Segmentation Principles
Role Segmentation Across Teams
Documentation Examples
Common Denial Triggers and Prevention
Compliance Checklist
1. CCM Overview in the Billing Context
CCM refers to the non-face-to-face care coordination of Medicare patients with two or more chronic conditions expected to last at least 12 months, at significant risk of decline or death.
Typical CPT/HCPCS codes include:
2. Common Concurrent Billing Combinations
CCM + RPM
Allowed if time and scope are distinct (e.g., CCM for overall care plan, RPM for physiologic monitoring).
Separate documentation of activities is required.
CCM + PCM
Permitted when PCM addresses a single high-priority condition, and CCM covers the broader chronic condition set.
Avoid overlap in documented care plan elements.
CCM + TCM
TCM is a 30-day post-discharge service; CCM can start after TCM ends or run concurrently if monthly criteria are met without duplication.
CCM + BHI
Behavioral Health Integration services may be billed with CCM if time and scope are distinct, and each has its own care plan segment.
3. CMS Guidelines: Permissible Combinations and Restrictions
CMS allows concurrent billing of CCM with other services when:
Each service meets all requirements independently
Time and tasks are non-duplicative
Care plan documentation clearly distinguishes between services
Staff and providers are acting within scope and supervision rules
4. Time Segmentation Principles
Service | Minimum Time | Scope Example |
|---|---|---|
CCM 99490 | 20 min/month | Medication management, referrals, care plan updates |
RPM 99457 | 20 min/month | Device data review, interactive communication |
PCM 99426 | 30 min/month | Focused management of one chronic condition |
BHI 99484 | 20 min/month | Behavioral health care coordination and follow-up |
Rule: Log time separately for each service. Do not count the same interaction toward multiple services.
5. Role Segmentation Across Teams
Assign tasks to avoid overlap:
CCM – Care coordinators and nursing staff updating care plans, medication management, and specialist communication.
RPM – Monitoring staff reviewing device data and contacting patients about readings.
PCM/BHI – Providers or staff focusing on targeted conditions.
Use EMR tags or dedicated care management software to track staff time per service.
6. Documentation Examples
CCM 99490
“Reviewed lab results, reconciled medications, coordinated cardiology and endocrinology follow-up, updated care plan goals. 25 minutes of clinical staff time.”
RPM 99457 (Concurrent Month)
“Reviewed 16 days of BP readings, contacted patient to discuss high AM readings. Adjusted monitoring frequency. 21 minutes interactive time.”
7. Common Denial Triggers and Prevention
Denial Reason | Prevention Tip |
|---|---|
Overlapping time logs | Maintain separate logs and timestamps for each service |
Care plan duplication | Document unique goals and interventions for each billed service |
Missing consent | Obtain and record patient consent for each program |
Insufficient documentation | Include duration, staff role, and specific tasks in each note |
8. Compliance Checklist
Documented rationale for concurrent CCM and other service billing
Separate time logs for each service
Distinct care plan sections or documents for each program
Patient consent documented for each service type
Activities meet CPT definitions without duplication
EMR or care coordination platform supports time and role segmentation
Staff trained on concurrent billing rules and modifiers
Monthly internal audit to ensure compliance with CMS guidelines
Reference to current CMS Final Rule and payer-specific policies
Final Note
Concurrent billing for CCM and related services can expand care capacity and revenue when done correctly. With disciplined time tracking, clear documentation, and role-based workflows, practices can improve outcomes while meeting compliance standards.
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