Chronic Care Management (CCM) and Transitional Care Management (TCM) codes, launched in 2015, sought to reimburse primary care providers for managing patients complex medical needs and were billed in 20-minute increments. In 2022, CCM was billed 4.59 million times by 13,600 practitioners for over 1 million Medicare beneficiaries.

In 2025, CMS approved new Advanced Primary Care Management (APCM) codes, which payout based on patient complexity instead of provider time. This is a first of its kind structural shift in reimbursement and is critical for technology innovation. Now, technology can be built to scale the delivery of chronic care services without a direct negative impact to the provider’s reimbursement.

Care management and navigation are the connective tissue of the healthcare system—guiding patients to the right care at the right time. They reduce unnecessary costs, prevent fragmentation, and ensure better outcomes by making care more coordinated and proactive.

Today, there is a significant gap that the system can’t solve with people, requiring this to be at the forefront of technology innovation in healthcare. The APCM codes are an early signal that reimbursement pathways will move in that direction. This is a window into the future, and other care navigation codes like recently launched principal illness navigation or remote patient monitoring should move to a task or per patient per month based structure in the coming years, enabling more innovation across the board.

Who is Eligible?

CMS broadened the addressable patient population from the original chronic care management codes by including a tier for patients with none to 1 chronic condition, meaning 100% of a provider’s patient population could be covered. At the same time, $15 per patient per month reimbursement is below the hourly minimum wage in most states - it’s clear this was designed with technology in mind!

What Services are Covered?

The goal of APCM is to provide holistic and continuous support for a patient, collapsing the disaggregated experience of accessing care today. CMS believes the PCP should be at the center of this experience, and in charge of coordination and navigation of services. The reality is, there is a PCP shortage, and the APCM payouts are lower than a PCP accepting an incremental FFS patient, misaligning incentives for PCPs to take on this role.

APCM’s billing structure enables PCPs to still be at the helm as they remain in charge of care plan creation and monitoring of a patient’s holistic care, but aren’t required to perform tasks in 20 minute increments at the expense of taking on new patients.

Amongst the 13 criteria for APCM, these components are both highly productizable and cost prohibitive for providers to deliver at the current reimbursement level - a clear opportunity for a technology platform to emerge. Several leading technology companies have solutions for many of the APCM workflows.

Billing

There are a few complexities with APCM that could support having an independent platform for billing. Patients cannot receive both APCM and CCM / TCM services at the same time, billing on a per patient per month basis is different from a PCP’s typical time-based rate, and tracking initiation of coverage every 3 years and associated prior auths is complex.

Looking Forward

With nearly $1 billion in CCM reimbursement last year alone, combining homegrown capabilities with existing technology to offer a purpose-built APCM platform is a compelling opportunity. But beyond the immediate potential, my excitement lies in what this signals for the future of tech-enabled care delivery. Few codes so clearly align with automation as this one, and it sets an encouraging precedent. If CMS continues down this path, we could be on the cusp of a new era where technology is not just an enabler but a core driver of care delivery models.