CCM Consent and Care Plan Requirements for 2026

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

Chronic Care Management (CCM) consent is a patient's verbal or written agreement, given once before billing starts and documented in the chart, after you explain cost sharing, the one billing practitioner rule and the right to stop. Medicare also requires a comprehensive electronic care plan, though CMS calls its elements typical rather than strict (CMS MLN booklet, June 2025).

As a psychologist, I'd say the consent conversation is the first real care conversation a patient has with your program, so it's worth doing well.

Key facts

• Consent can be written or verbal, and CMS has allowed verbal consent since the CY 2017 fee schedule final rule (CMS CCM FAQs, updated August 2022).
• Consent is needed once before CCM starts, not monthly or yearly, and again only if the patient changes billing practitioners (CMS CCM FAQs, 2022).
• The chart must show five things: CCM is available, cost sharing may apply, only one practitioner can bill in a calendar month, the patient can stop at any time, and the patient accepted or declined (CMS MLN booklet, June 2025).
• CMS lists 12 typical care plan elements and says they aren't a strict set of requirements (CMS CCM FAQs, 2022).
• The care plan must be electronic, shared promptly inside and outside the practice, and given to the patient or caregiver when necessary (CMS MLN booklet, 2025).
• If the patient doesn't consent, you can't bill Medicare or the patient for CCM, and an ABN isn't appropriate (CMS CCM FAQs, 2022).
• In the CY 2027 proposed rule, issued July 14, 2026, CMS asked how to simplify care management codes, citing cost sharing and documentation as barriers to use (ACP summary, 2026).

What does Medicare require for CCM patient consent?

Medicare requires the patient's written or verbal consent before you bill CCM, and you have to record in the chart that you explained five items. CMS says this helps patients understand their cost sharing and helps prevent two practices billing the same patient in the same month.

Here's the checklist from the CMS booklet:

• Availability. Tell the patient CCM services exist and what they include.
• Cost sharing. Explain that coinsurance may apply.
• One practitioner. Explain that only one practitioner can furnish and bill CCM in a calendar month.
• Right to stop. Explain that the patient can stop at any time, effective at the end of the calendar month.
• Outcome. Document that you explained all of this and whether the patient accepted or declined.

The CMS toolkit adds that the record should show the patient agreed to take part, was told they can stop, and was told only one professional can provide CCM in a month, with cost sharing information included as well (CMS CCM toolkit).

Consent is a one time event. There's no monthly or annual renewal in the federal rules. Your payer contracts may ask for more, so check them.

What should the consent note in the chart say?

The consent note should be short, dated and specific. A reviewer should be able to read it and see all five items without guessing. Vague entries like "CCM discussed" are the ones that cause trouble in an audit.

Here's a structure you can adapt to your own EHR:

1. Date, patient and who spoke. Record who had the conversation and how it happened: in person, by phone or by portal.
2. What was explained. List the five items in plain words, one per line.
3. The decision. State "accepted" or "declined" in the patient's words if you can.
4. Who the billing practitioner is. This matters because the one practitioner rule is tied to a named person.
5. Where the patient's copy or follow up is. If you gave written material, say so.

Some practices use a signed form and others a templated note for verbal consent. The CMS toolkit says informed consent can be verbal, and you may also choose an electronic or paper form (CMS CCM toolkit).

One more point. Consent to CCM isn't the same as permission to call a patient with automated or artificial voice technology. Those are separate questions with separate rules, and we cover the second one in our post on AI voice calls and the TCPA healthcare exemption.

Does consent have to happen at the initiating visit?

No. The initiating visit and consent are two separate requirements, and CMS says consent doesn't have to be obtained at the initiating visit. The visit is still an easy place to do it.

The initiating visit is required for new patients and for patients the billing practitioner hasn't seen in the previous year. It has to be a comprehensive face to face visit: a level 2 to 5 office visit (99212 to 99215), an annual wellness visit, an initial preventive physical exam, or the face to face visit in a TCM service. The billing practitioner must discuss CCM at that visit. If you don't, the visit can't count as the initiating visit (CMS CCM FAQs, 2022).

The visit isn't part of CCM and can be billed on its own. Its time doesn't count toward the monthly CCM minutes.

So the sequence can look like this. The practitioner raises CCM at the visit and notes it. Clinical staff then complete the consent conversation by phone a few days later, when the patient has had time to think about the monthly cost. Both steps need a note. Neither should be skipped.

What must a CCM comprehensive care plan include?

A CCM care plan is a patient centered electronic plan based on a physical, mental, cognitive, psychosocial, functional and environmental assessment and an inventory of resources and supports. CMS lists typical elements but says they aren't strict requirements. They reflect what's typically, but perhaps not always, included as medically appropriate for the patient (CMS CCM FAQs, 2022).

The typical elements are:

• Problem list
• Expected outcome and prognosis
• Measurable treatment goals
• Cognitive and functional assessment
• Symptom management
• Planned interventions
• Medical management
• Environmental evaluation
• Caregiver assessment
• Interaction and coordination with outside resources and practitioners

The MLN booklet also lists revision and monitoring, and periodic review, which brings the total to 12 (CMS MLN booklet, 2025).

CMS also expects the plan to be made available promptly within and outside the billing practice, and to be given to the patient or caregiver when necessary. Separately, the practice must record demographics, problems, medications and medication allergies in certified EHR technology, and that list has to inform the plan.

How do you document the care plan so it holds up?

Document the plan as a living record, not a one time form. CMS describes the plan as something you create, revise and monitor, so the chart should show it being used.

A simple routine:

1. Build the first plan from the assessment. Pull the problem list, medications and allergies from the structured EHR fields, then add goals the patient agrees to.
2. Write goals you can measure. "Home blood pressure under the target your practitioner sets, checked three times a week" is easier to review than "control blood pressure."
3. Record what was shared and with whom. Note the date the patient or caregiver received a copy and which outside clinicians got it.
4. Revise after real events. Update after an ED visit, a discharge, a medication change or a new referral.
5. Log who did the work. Time counts only when clinical staff are acting under the practitioner's supervision, and the billing practitioner's own oversight can't be delegated.

On that last point, CMS allows outside clinical staff to deliver the staff portion of CCM when the incident to rules are met. If there's little oversight or a lack of clinical integration, CMS says the practitioner shouldn't bill. General supervision means the practitioner's overall direction and control, without needing to be present (42 CFR 410.26).

What happens if the patient declines or you skip consent?

If the patient doesn't consent, you can't bill Medicare or the patient for CCM. CMS says any CCM work you did is treated as included in payment for the face to face visits, and you shouldn't issue an ABN because CCM is considered a reasonable and necessary covered service (CMS CCM FAQs, 2022).

The same logic applies to missing paperwork. Consent, the care plan and the initiating visit are conditions of payment. A month with the time met but no documented consent isn't a billable month.

Record a declined consent too, rather than leaving it blank. A clear "declined" tells the next person who opens the chart not to start from scratch.

A policy backdrop is worth knowing. In the CY 2027 proposed rule, CMS said use of care management codes has been limited and invited comment on simplifying the code set and standardizing requirements across it. That's a request for information, not a change to consent or care plan rules. Today's requirements still apply until CMS says otherwise (CMS CY 2027 proposed rule fact sheet, July 2026).

What this means for your practice

Audit your own charts first. Pull ten CCM patients at random and check for a dated consent note with all five items, a care plan with a revision date, and proof the patient got a copy. Gaps are easier to fix before a payer finds them.

Next, write down who does what. Decide who has the consent conversation, who builds and revises the care plan, and how the billing practitioner stays involved. Put it in a one page procedure so new staff follow the same steps.

Then make the consent conversation short and honest. Mention the coinsurance up front, since cost sharing is one of the reasons patients say no. If a patient has Medigap, CMS says it covers the coinsurance for Part B services.

HANA Health helps practices run care management outreach between visits. You can see how at HANA Remote. For the full picture of eligibility, codes and payment, start with our guide to chronic care management, and see why APCM and CCM can't be billed together.

Frequently asked questions

Can a patient give CCM consent over the phone?

Yes. CMS allows verbal consent, so a phone conversation works as long as you document it in the chart. The note should show the five items you explained and the patient's decision.

Do I need new consent if the patient moves to another practice?

The new billing practitioner needs their own consent, documented before they furnish the service. CMS says consent is needed again only when the patient changes billing practitioners.

Can a patient stop CCM in the middle of a month?

They can ask to stop at any time, but the stop takes effect at the end of the calendar month. Record the request and the effective date so billing stops on the right month.

Does the patient have to receive a copy of the care plan?

CMS says to make the plan available promptly inside and outside the practice, and to give patients and caregivers a copy when necessary. Record the date and method so you can show it was shared.

Will Medigap pay the patient's CCM coinsurance?

CMS says Medigap insurers can't deny coinsurance for a service covered under Part B, unless the policy has a deductible that hasn't been met. Dually eligible patients have different rules by state.

Sources

1. Centers for Medicare & Medicaid Services, Medicare Learning Network, Chronic Care Management Services (MLN909188), June 2025.
2. Centers for Medicare & Medicaid Services, Chronic Care Management Frequently Asked Questions, updated August 2022.
3. Centers for Medicare & Medicaid Services, Chronic Care Management Toolkit.
4. Electronic Code of Federal Regulations, 42 CFR 410.26, Services and supplies incident to a physician's professional services.
5. Centers for Medicare & Medicaid Services, Calendar Year 2027 Medicare Physician Fee Schedule Proposed Rule fact sheet, July 14, 2026.
6. American College of Physicians, Summary of the 2027 Physician Fee Schedule Proposed Rule, 2026.

This article is educational and isn't billing, coding, clinical or legal advice. Check current CMS guidance and your MAC before you bill. If you'd like to talk through care management for your practice, you can book a call with Matteo.