Top 7 Reasons for Claims Denials in CCM, RPM, and TCM – and How to Avoid Them

OnCare360

Sep 8, 2025

Chronic Care Management (CCM), Remote Patient Monitoring (RPM), and Transitional Care Management (TCM) offer strong opportunities to improve patient outcomes while generating recurring Medicare revenue. Yet many practices encounter denials that undermine both compliance and reimbursement.

This article highlights the seven most common denial reasons for these programs and provides practical strategies to prevent them.

Why Denials Happen

CMS and commercial payers scrutinize care management services closely because they involve time-based codes, recurring claims, and overlapping programs. Denials most often result from documentation errors, missing requirements, or billing duplication rather than ineligibility.

1. Missing or Incomplete Patient Consent

Problem: CMS requires documented patient consent for CCM, RPM, and TCM. Without clear consent in the record, claims are at risk.
Avoidance Strategy: Capture consent (verbal or written) at enrollment and log it in the EHR with date, staff attribution, and acknowledgment of cost-sharing.

2. Insufficient Time Documentation

Problem: Codes such as CCM (99490 – 20 minutes) and RPM (99457 – 20 minutes) require minimum monthly time. Missing or vague logs trigger denials.
Avoidance Strategy: Use automated time tracking tools and ensure staff record start/stop times, staff roles, and patient activities.

3. Service Duplication or Overlap

Problem: Billing both CCM and PCM, or RPM and CCM, for overlapping time or identical activities.
Avoidance Strategy: Distinguish activities by service type and maintain separate logs. Document rationale if multiple care management services are billed in the same month.

4. Device or Data Requirements Not Met (RPM)

Problem: RPM claims are denied if devices do not transmit at least 16 days of data in a 30-day period (unless using new 2026 codes for 2–15 days).
Avoidance Strategy: Audit device transmission monthly and flag patients falling below thresholds. Educate patients on consistent device use.

5. Missed Contact or Visit Timelines (TCM)

Problem: TCM requires interactive contact within 2 business days of discharge and a face-to-face visit within 7 or 14 days depending on complexity. Missed deadlines lead to denials.
Avoidance Strategy: Build hospital discharge alerts into workflows and assign responsibility for 2-day calls. Schedule face-to-face visits before discharge whenever possible.

6. Lack of Comprehensive or Shareable Care Plan

Problem: CCM and PCM require a comprehensive care plan accessible to the care team and patient. Generic or absent plans are a red flag for auditors.
Avoidance Strategy: Use structured templates with diagnoses, medications, measurable goals, and responsible clinicians. Update monthly and store in a shareable format.

7. Billing by Multiple Providers for the Same Service

Problem: CMS only allows one provider to bill CCM or TCM per patient per month. Duplicate claims across providers are denied.
Avoidance Strategy: Confirm at enrollment who will serve as the billing provider. Document care responsibility in the record.

Key Takeaways

Denials for CCM, RPM, and TCM usually arise from process failures, not eligibility.
Practices can prevent most issues by reinforcing consent, time tracking, documentation, and role clarity.
Regular internal audits and staff training reduce risk and ensure compliance with CMS requirements.

Conclusion

CCM, RPM, and TCM remain high-value programs for both patients and providers. With careful attention to documentation and workflow, practices can avoid denials, safeguard revenue, and stay audit-ready.