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Hana Health
Care ManagementOctober 28, 2026

Which Medicare Care Management Codes Can You Bill in the Same Month?

Matteo

Updated October 2026. Written by Matteo Grassi, clinical psychologist and cofounder of HANA Health.

Same month billing means reporting two or more Medicare care management services for one patient in one calendar month. CMS allows it when each service is separately consented, documented and never counts the same minutes twice. In 2026, CCM can pair with TCM, BHI, CoCM and either RPM or RTM, but not with PCM or APCM from the same practitioner.

I've sat on both sides of the patient call, and the confusion here is rarely about a rule. It's about who owns the month.

Key facts

  • Only one practitioner can provide and bill CCM for a patient in a calendar month, per the CMS CCM booklet (MLN909188, June 2025).
  • CCM codes 99487, 99489, 99490 and 99491 can be reported during the 30 day TCM period, per the same CMS CCM booklet.
  • CMS says CCM and PCM can't be billed by the same practitioner for the same patient in the same month, per the CMS CCM FAQ, citing the CY2020 final rule.
  • A single practitioner must choose either general BHI or CoCM for a patient in a given month, per the CMS BHI FAQ.
  • APCM is billed once per patient per calendar month, per the CMS APCM page.
  • Three optional APCM add on codes for BHI and CoCM (G0568, G0569, G0570) took effect January 1, 2026, per the CMS APCM page.
  • CMS allows either RPM or RTM, but not both, alongside CCM or TCM, per the CMS CCM booklet.

Which Medicare care management codes can be billed in the same month?

Most of them can, with a handful of hard stops. CMS lets you report different care management services for one patient in one month when each is medically necessary, separately consented and documented, and no minute of work counts toward two codes.

Here's the pairing grid in plain terms:

  • CCM with TCM: allowed. CCM can run during the 30 day TCM period.
  • CCM with PCM: not from the same practitioner for the same patient.
  • CCM with BHI or CoCM: allowed when both services meet their own requirements.
  • CCM with RPM or RTM: allowed, but you pick one of RPM or RTM, not both.
  • Practitioner CCM with staff or complex CCM: not in the same month. Codes 99491 and 99437 can't share a month with 99487, 99489, 99490 or 99439.
  • CCM with home health or hospice supervision (G0181, G0182) or ESRD services (90951 through 90970): not in the same service period.
  • BHI with CoCM: not in the same month. Pick one.
  • APCM with CCM, PCM or TCM: not for the practitioner billing APCM.
  • APCM with BHI or CoCM: allowed through the dedicated add on codes.

For a deeper code by code view of CCM itself, see our guide to CCM billing codes.

Can CCM and TCM be billed in the same month?

Yes. CMS's CCM booklet says you can report 99487, 99489, 99490 and 99491 for services provided during the 30 day TCM period, which covers 99495 and 99496. The TCM booklet says other care management services can be billed alongside TCM when they're medically reasonable and necessary and the time and effort aren't counted more than once.

You may have read older advice that CCM had to wait until TCM ended. CMS guidance from 2016 was tighter, and the CY2020 final rule relaxed it. If a consultant's checklist still says to wait, it's out of date.

The practical risk is overlap. A call that confirms a discharge medication change can count toward TCM. It can't also count toward CCM minutes. Keep a separate time log per service.

If you're working through the discharge side, our explainer on TCM requirements for 99495 and 99496 covers the two business day contact and the visit windows.

Can CCM and PCM be billed in the same month?

Not by the same practitioner for the same patient. CMS says in its CCM FAQ that CCM and PCM can't be billed by the same practitioner for the same patient in the same month. A primary care practitioner can offer CCM while a specialist offers PCM, and the conditions being addressed must be different.

When both run at once, CMS says two care plans are required. The PCM plan only needs to be disease specific, while the CCM plan covers the whole patient.

This is the pairing that surprises multispecialty groups. The rule follows the billing practitioner, not the group, so two clinicians in one practice can each bill one of them if the conditions don't overlap. Check your consent language, because the patient should know that more than one program may apply.

For when PCM fits better than CCM, see Principal Care Management explained.

Can APCM be billed with CCM, PCM or TCM?

No, not by the practitioner who bills APCM. CMS built Advanced Primary Care Management as a bundle that includes elements of PCM, TCM and CCM, plus communication services such as virtual check ins and interprofessional consultations. In the CY2025 final rule, CMS treated those services as duplicative in a month when APCM is billed. As I read the rule, a different practitioner can still bill them when medically necessary, but confirm that with your MAC before you build a workflow on it.

APCM isn't time based. You bill one of three codes once a month based on the patient's complexity, and only one practitioner can bill it.

Since January 1, 2026, CMS has also offered three optional add on codes. G0568 and G0569 cover psychiatric CoCM, and G0570 covers general BHI, all billed alongside an APCM base code in the same month.

We wrote about the choice between the two programs in why APCM and CCM can't be billed together.

Can BHI or CoCM be billed with CCM?

Yes, with conditions. The CMS BHI FAQ says the BHI codes can be billed for the same patient in the same month as CCM if advance consent for both services is obtained, all requirements for each service are met, and time and effort aren't counted more than once. Cost sharing and consent apply to each service separately, and only one practitioner can report CCM in a month.

CMS also says a single practitioner must choose between general BHI and the CoCM codes in a given month. They can switch from one month to the next.

There's one more nudge in the FAQ. If a BHI code describes the service more specifically than a CCM code, CMS says the BHI code is the more appropriate one to report. For a patient whose main need is depression or anxiety, that points toward BHI or CoCM first.

For the basics, see what BHI is and how 99484 works.

How do RPM and RTM fit alongside CCM and TCM?

You can bill one of them with CCM or TCM, not both. The CMS CCM booklet says you can bill either remote physiologic monitoring or remote therapeutic monitoring, but not both, concurrently with any CCM or TCM service.

Keep a close eye on this area for 2027. CMS published its CY2027 proposed rule on July 16, 2026, and comments closed on September 14, 2026. The CMS fact sheet says CMS proposes allowing payment for RPM or RTM only when clinical staff employed by the practice furnish the services, not contractors. CMS also asked for comments on bundling the RPM and RTM codes into four new HCPCS codes.

As of this writing, the final rule hasn't been released. Nothing in the fact sheet's remote monitoring section changes the CCM, TCM or PCM pairing rules above, but only the final rule counts.

Our post on RPM versus RTM covers how the two code families differ.

What this means for your practice

Pairing programs is a revenue question and a compliance question. The same patient can generate more than one claim in a month, so your process has to prove that each claim stands on its own.

  1. Pick a lead program for each patient and write down why. A patient with two or more chronic conditions and a recent discharge may need TCM first and CCM afterward.
  2. Capture consent for each program, including cost sharing and the one practitioner rule.
  3. Log minutes by service. No minute should appear in two programs.
  4. Check who else bills for the patient. Only one practitioner can bill CCM in a month, and the same goes for APCM.
  5. Add claim edits for the hard stops: practitioner CCM with staff CCM, CCM with PCM, BHI with CoCM, and APCM with CCM, PCM or TCM.

HANA Health works with practices on care management outreach, including the patient calls that sit behind these programs. You can read more on the HANA Remote page.

Frequently asked questions

Can I bill CCM in a month when the patient also has an office visit?

CMS doesn't bar visits in a CCM month. The CCM booklet says you can't count time toward the CCM code for any other billed code, so the visit time stays with the visit. Document the two separately.

Can two practices bill CCM for the same patient in the same month?

No. Patients are told at consent that only one practitioner can provide and bill CCM in a calendar month. If another practice already bills it, your claim can be denied.

Can I bill RPM and RTM together with CCM?

No. CMS allows either RPM or RTM, but not both, concurrently with any CCM or TCM service.

Does the CY2027 proposal change these pairing rules?

The proposal described in CMS's fact sheet focuses on remote monitoring, not on how CCM, TCM, PCM or BHI pair. The final rule usually arrives in early November, so recheck the remote monitoring rules once it's out.

Sources

  1. Centers for Medicare & Medicaid Services, Chronic Care Management Services (MLN909188), June 2025.
  2. Centers for Medicare & Medicaid Services, Transitional Care Management Services (MLN908628).
  3. Centers for Medicare & Medicaid Services, Chronic Care Management Frequently Asked Questions, 2022.
  4. Centers for Medicare & Medicaid Services, Frequently Asked Questions about Billing Medicare for Behavioral Health Integration Services, 2023.
  5. Centers for Medicare & Medicaid Services, Advanced Primary Care Management Services.
  6. Federal Register, CY2025 Payment Policies Under the Physician Fee Schedule, December 9, 2024.
  7. Centers for Medicare & Medicaid Services, CY2027 Medicare Physician Fee Schedule Proposed Rule fact sheet, July 2026.

This article is educational and isn't billing, coding, clinical or legal advice. Check current CMS guidance and your MAC before you bill.

Want to talk through how these programs fit together in your practice? Book a discovery call with Matteo.