A New Payment Model That Reflects How Primary Care Actually Works
For years, primary care clinicians have been doing work that the fee-for-service system simply didn’t pay for: managing complex patients between visits, coordinating care across specialties, reaching out to high-risk individuals before a crisis, and keeping continuity alive in a fragmented system. That work was invisible in the payment model — and that invisibility had consequences.
Advanced Primary Care Management (APCM), launched by the Centers for Medicare & Medicaid Services (CMS) on January 1, 2025, changes that calculus. For the first time, Medicare is offering primary care practices a monthly bundled payment that captures the full scope of care management — without the administrative burden of minute-by-minute time tracking that made earlier programs like Chronic Care Management so difficult to scale.
The Primary Care Collaborative (PCC) has been active in this policy development from the beginning — engaging CMS leaders, practice representatives, and health system stakeholders to shape the program, provide feedback, and help the field understand how to put APCM into practice. Our recent webinar, “Advanced Primary Care Management: Successful Implementation,” brought those conversations to life with direct insights from the organizations implementing this program on the ground.
Why APCM Is a Meaningful Step Forward
What makes APCM genuinely different is what it doesn’t require. Unlike time-based care management codes, practices do not need to document every minute spent on patient management to bill APCM. Instead, they must demonstrate capacity across 13 service elements — including 24/7 care access, care plan development, transitional care management, behavioral health coordination, and risk stratification — and deliver them as clinically appropriate for each patient. This is how high-performing primary care teams have always operated. APCM simply creates a payment structure that reflects that reality.
APCM is structured around three billing codes — G0556, G0557, and G0558 — tiered by patient complexity. Patients with one or fewer chronic conditions qualify for Level 1; those with two or more qualify for Level 2; and patients who are both medically complex and Qualified Medicare Beneficiaries — among the most vulnerable and costly patients in the Medicare population — qualify for Level 3. Reimbursement rates increased approximately 10 percent in the 2026 Medicare Physician Fee Schedule and CMS has continued to expand the program by creating add-on codes for behavioral health–an important sign that CMS is committed to growing this program.
WHAT APCM COVERS
APCM bundles 13 service elements into a single monthly payment: patient consent, initiating visit, 24/7 access to care, continuity of care, comprehensive care management, care plan creation and revision, management of care transitions, coordination with community-based services, ongoing patient communication, enhanced communication using health IT, population-level data analysis, risk stratification, and performance measurement. Practices must be capable of delivering all 13 — but not every element is required each month.
What Practices Are Experiencing on the Ground
Our webinar surfaced practical, on-the-ground insights from practices that have moved beyond the planning stage and are actively billing APCM for their Medicare patients. Several key themes emerged.
The administrative relief is real. The shift away from time-based documentation has freed clinical staff to focus on patient care rather than stopwatch management. For practices that struggled with the documentation requirements of Chronic Care Management, APCM has proven to be a more sustainable model — one that aligns with how care teams naturally work.
Patient engagement is improving. The structure of APCM — with its emphasis on proactive outreach, care planning, and between-visit communication — is strengthening the longitudinal relationships that define high-quality primary care. Patients enrolled in APCM hear from their care team more consistently, and that continuity is producing measurable benefits in chronic disease management and care gap closure.
The revenue matters. For independent and small practices operating on thin margins, the predictable monthly APCM payment provides a financial stabilizer. The program does not require the infrastructure investment of more complex alternative payment models, making it accessible across the full range of primary care settings — including federally qualified health centers and rural health clinics, which became eligible for APCM billing beginning mid-2025.
PCC’s Role: Shaping the Program and Advocating for Improvement
The Primary Care Collaborative has been a consistent and influential voice in APCM’s development. In July 2024, the PCC convened an online discussion with senior CMS leaders — including Dr. Meena Seshamani, Deputy Administrator and Director of the Center for Medicare, and Dr. Doug Jacobs, Chief Transformation Officer of the Center for Medicare — to examine how the new APCM codes could strengthen primary care under the Physician Fee Schedule. That forum helped translate CMS’s policy intentions into practical understanding for the primary care community and surfaced critical feedback from practices on the ground.
The PCC has sustained that engagement as APCM has moved from proposal to implementation. Our advocacy has focused on the areas where the program can go further: reducing patient cost-sharing, which remains a barrier to enrollment for many Medicare beneficiaries and an administrative burden for practices; expanding APCM so that it could function as a hybrid payment; and ensuring that safety net providers and the communities they serve can fully access the program’s benefits.
Those advocacy efforts are producing results. Following recommendations from the PCC and its members, the 2026 Medicare Physician Fee Schedule included new behavioral health add-on codes for APCM — a direct response to the PCC’s long-standing position that mental health integration is a core component of advanced primary care. CMS has also signaled openness to incorporating more preventive care services into the bundle, another PCC priority.
PCC’S ONGOING APCM PRIORITIES
The PCC continues to work with CMS and Congressional stakeholders to: reduce or eliminate cost-sharing requirements that limit APCM enrollment; develop hybrid payment models that build on APCM infrastructure; ensure that safety net practices serving Medicaid and dually eligible patients can fully participate; and promote alignment between Medicare, Medicaid, and commercial payers on APCM framework to reduce fragmentation.
What Comes Next
APCM is explicitly described by CMS as a multi-year effort — a first step toward something more comprehensive. The agency has signaled interest in developing a hybrid payment model that combines APCM’s population-based monthly payment with traditional fee-for-service for appropriate services, creating a more complete infrastructure for team-based, whole-person primary care.
This is the direction the PCC has championed, and the direction the evidence supports. Health systems and payers that align their contracting strategies, care team design, and technology investments with APCM’s framework now will be well-positioned as this evolution continues. We are seeing that the practices that adopt APCM today are not just capturing revenue — they are building the workflows, patient relationships, and population health competencies that will define high-performing primary care for the decade ahead.
Watch the Webinar and Join the Conversation
If you weren’t able to join us live for “Advanced Primary Care Management: Successful Implementation,” the recording is now available on demand. Our speakers, Dr Jake Quinton, CMS; Dr Sam Hiatt, Community Care of North Carolina; Cristina Boccuti, AARP; Dr Jason Lofton, Lofton Family Clinic explored the practical realities of APCM adoption, answered questions from practices at every stage of implementation, and discussed what the next phase of primary care payment transformation looks like.
Whether you are a practice administrator evaluating APCM for the first time, a health system leader thinking about how to support your primary care network, or a payer looking to align contracting strategy with this emerging model — this webinar offers concrete, actionable perspective.
Watch the Webinar On Demand
Click here to watch “Advanced Primary Care Management: Successful Implementation”. For questions about APCM, PCC membership, or how to engage with PCC’s advocacy on primary care payment reform, reach out to PCC’s Policy Director, Larry McNeely (lmcneely@thepcc.org).
The Primary Care Collaborative will continue to convene, inform, and advocate as APCM matures. We invite you to be part of that work.
This blog was originally posted by PCC Board Chair Sean Hogan on LinkedIn. Click here to read the original post.