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Chronic care management is not a visit, and that single fact resolves most of the confusion family medicine practices have about it. CCM is a monthly, time-based, largely non-face-to-face service billed for care coordination that happens between visits. The office visit is a separate, separately payable thing. The two coexist — but only if the practice understands which minutes belong to which, and which combinations Medicare forbids outright.
This page sets out the eligibility test, the code structure, the initiating-visit requirement that trips up new programmes, and the concurrent-billing prohibitions that generate recoupments.
Verified against the CMS Medicare Learning Network booklet “Chronic Care Management Services,” MLN909188, June 2025; the CMS Physician Fee Schedule page “Chronic Care Management for Complex Conditions,” last modified 20 January 2026; and American Academy of Family Physicians billing and coding guidance. CPT codes and descriptions are copyright the American Medical Association.
Who Is Eligible
CMS defines the patient test precisely. Eligible patients have “multiple (2 or more) chronic conditions expected to last at least 12 months, or until their death,” and those conditions “place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline.”
CMS lists examples of qualifying chronic conditions, explicitly non-exhaustive: Alzheimer’s disease and related dementia, arthritis (osteoarthritis and rheumatoid arthritis), asthma, atrial fibrillation, autism spectrum disorders, cancer, cardiovascular disease, chronic obstructive pulmonary disease, depression, diabetes, glaucoma, HIV and AIDS, hypertension, and substance use disorders.
CMS also suggests practices may identify candidates “using criteria suggested in CPT guidance (such as number of illnesses, number of medications, or repeat admissions or emergency department visits).”
The Code Structure
CCM codes are organised on two axes: who performed the time, and how much of it. From the CMS booklet’s applicable-codes table:
| Code | Care type | Staff type | Time |
|---|---|---|---|
| 99490 | Chronic care management | Clinical staff | First 20 minutes |
| +99439 | Chronic care management | Clinical staff | Each additional 20 minutes |
| 99491 | Chronic care management | Physician or other QHP | First 30 minutes |
| +99437 | Chronic care management | Physician or other QHP | Each additional 30 minutes |
| 99487 | Complex chronic care management | Clinical staff | First 60 minutes |
| +99489 | Complex chronic care management | Clinical staff | Each additional 30 minutes |
Two rules govern whose minutes count, and they are frequently confused:
- 99487, 99489, 99490 and 99439 “include time spent directly by the billing practitioners or clinical staff. Time spent by the billing practitioner may also count toward the time threshold if not used to report 99491.”
- 99491 and 99437 “include only time that’s spent personally by the billing practitioner. Clinical staff time doesn’t count toward the required reporting time threshold code.”
The distinction between complex and non-complex CCM turns on medical decision making. Per the CMS required-elements table, complex CCM requires “moderate or high complexity medical decision making”; non-complex CCM has no MDM requirement. Both require two or more qualifying chronic conditions and a comprehensive care plan established, implemented, revised or monitored.
CMS assigns the clinical-staff codes (99487, 99489, 99490 and 99439) a general supervision level, meaning “the billing practitioner doesn’t personally provide the service but it’s done under their overall direction and control,” and CMS does “not require you to be physically present during the service.”
The Initiating Visit — Where the Office Visit Comes In
This is the direct answer to the CCM-versus-office-visit question, and CMS states it in two parts.
First, the requirement: “Before CCM services can start, we require an initiating visit for new patients or patients who you haven’t seen within the previous 1 year.” That visit must be “a comprehensive face-to-face evaluation and management (E/M) visit, annual wellness visit (AWV), or initial preventive physical exam (IPPE).”
Second, the condition that catches practices: “If you don’t discuss CCM during an E/M visit, AWV, or IPPE, it can’t count as the initiating visit.” A qualifying visit that did not include a CCM discussion does not retroactively become an initiating visit.
And then the key payment point: “A face-to-face initiating visit isn’t part of CCM and can be separately billed.” The office visit is not absorbed. It is billed on its own terms, under the ordinary E/M rules.
CMS adds an optional add-on: “If you personally provide extensive assessment and care planning outside the usual effort described by the initiating visit and CCM codes, you may also bill HCPCS code G0506 once, as part of an initiating visit.”
Consent Is a Billing Prerequisite
CMS requires patient consent — “written or verbal” — before billing, and requires that the practice inform the patient of, and document, five specific items:
- The availability of CCM services
- Their possible cost-sharing responsibilities
- That only 1 practitioner can provide and bill CCM services during a calendar month
- Their right to stop CCM services at any time (effective at the end of the calendar month)
- That you explained the required information and whether the patient accepted or declined services
Consent is given once and does not need repeating “unless they switch to a different CCM practitioner.”
The Concurrent-Billing Prohibitions
This list is where recoupments come from, and it is worth reproducing carefully. Per the CMS booklet:
- You cannot report non-complex CCM and complex CCM for the same patient in a calendar month — specifically, do not report 99491 and 99437 in the same calendar month as 99487, 99489, 99490 or 99439.
- You cannot bill CCM during the same service period as HCPCS G0181 (home health care supervision), G0182 (hospice care supervision), or CPT 90951–90970 (certain ESRD services).
- You can report CCM codes 99487, 99489, 99490 and 99491 for services provided during the 30-day transitional care management service period (CPT 99495 and 99496).
- You cannot report complex CCM and prolonged E/M services in the same calendar month.
- You cannot count time toward the CCM service code for any other billed code.
- RHCs and FQHCs can bill CCM and TCM services for the same patient during the same period.
- You can bill either remote physiologic monitoring or remote therapeutic monitoring, but not both, concurrently with any CCM or TCM service.
The fifth item — “you can’t count time toward the CCM service code for any other billed code” — is the one that most often produces an unsupported claim. Minutes are not fungible. Time counted toward an office visit’s total time cannot also be counted toward the month’s CCM threshold.
Worked Example: A Month in a Family Medicine Panel
A 71-year-old with type 2 diabetes, hypertension and COPD has consented to CCM. During February:
- On 4 February she attends a scheduled office visit for a COPD exacerbation. The physician takes a history, examines her, adjusts inhaled therapy and arranges follow-up. The visit runs 25 minutes.
- Across the month, a practice nurse spends 35 minutes on care coordination: chasing a pending pulmonary function test, reconciling medications after a pharmacy substitution, calling to check inhaler adherence, and updating the electronic care plan.
Report: the office visit on 4 February as an ordinary office/outpatient E/M, selected under the normal rules; plus 99490 for the first 20 minutes of clinical staff CCM time, plus +99439 for the additional 20 minutes if the clinical staff time reaches that second threshold. On 35 minutes, 99490 alone is supported — the additional-20-minutes add-on requires the further increment to be met.
What must not happen: the 25 minutes of the office visit cannot be added to the 35 minutes of coordination to reach 60. Those are different services and different time pools, and CMS’s prohibition on counting CCM time toward any other billed code runs in both directions.
Related Care Management Services
CCM sits inside a family of monthly management services, and choosing the wrong one is a common error:
- Principal care management (PCM) — codes 99424, 99425, 99426 and 99427 — “focus on a single, high-risk chronic condition expected to last at least 3 months.” CMS requires another initial visit after one year to continue, and states “you can’t bill for PCM services of less than 30 minutes per calendar month.” PCM is the correct choice where there is one qualifying condition, not two.
- Advanced Primary Care Management (APCM) — codes G0556 (Level 1, 0 or 1 chronic condition), G0557 (Level 2, 2 or more chronic conditions) and G0558 (Level 3, 2 or more chronic conditions and Qualified Medicare Beneficiary status). APCM bundles elements of PCM, TCM, CCM, interprofessional consultations and online digital E/M, is billed once per calendar month, and — the operational attraction — does “not require you to count minutes per month to bill.”
- Chronic pain management — G3002 (first 30 minutes, physician or other QHP, must meet or exceed 30 minutes) and +G3003 (each additional 15 minutes, must meet or exceed 15 minutes). CMS requires the initial chronic pain management visit to be face-to-face and at least 30 minutes.
Who May Bill
CMS lists the eligible billing practitioners: physicians (MDs and DOs), certified nurse-midwives, clinical nurse specialists, nurse practitioners and physician assistants. CCM services “aren’t within the scope of practice of limited-license physicians and practitioners like clinical psychologists, podiatrists, or dentists,” though CCM practitioners may consult or refer to them.
For services the billing practitioner does not personally provide, “clinical staff can provide them under your direction on an ‘incident to’ basis.” The incident-to conditions are their own body of rules; our guide to incident-to billing and its conditional test, setting by setting works through them.
Frequently Asked Questions
Can we bill CCM and an office visit in the same month?
Yes. CCM is a monthly non-face-to-face service and the office visit is a separate service. CMS states directly that a face-to-face initiating visit “isn’t part of CCM and can be separately billed.” The constraint is that the same minutes cannot be counted twice.
Can two practices bill CCM for the same patient?
No. Only one practitioner can provide and bill CCM services during a calendar month, and CMS requires that the patient be told this as part of consent.
Does the patient have to consent in writing?
No — CMS accepts “written or verbal” consent, but the consent and the five required disclosures must be documented in the medical record.
Can we bill CCM during a transitional care management period?
Yes, for codes 99487, 99489, 99490 and 99491, during the 30-day TCM service period associated with 99495 or 99496. This is one of the few concurrent combinations CMS expressly permits.
What if the patient has only one chronic condition?
CCM does not apply — it requires two or more. Consider principal care management (99424–99427), which is built for a single high-risk chronic condition expected to last at least 3 months.
Does the billing practitioner need to be physically present while staff do the work?
No. CMS assigns 99487, 99489, 99490 and 99439 a general supervision level and states that it does not require the practitioner to be physically present during the service.
Can we count time spent by clinical staff toward 99491?
No. 99491 and 99437 “include only time that’s spent personally by the billing practitioner.” Clinical staff time does not count toward those thresholds.
