How to Bill for Chronic Care Management: A 7 Step Guide

To bill for chronic care management, you need six things in place before the claim goes out: an initiating visit for any patient you have not seen in a year, documented consent, an eligible patient with two or more qualifying chronic conditions, an electronic comprehensive care plan, at least 20 minutes of clinical staff time in the calendar month under general supervision, and a time log that shows who did what and when.

When those are true, you report 99490 once for the month, add 99439 for each additional 20 minutes, and choose a date of service that is either the day the time threshold was met or the last day of the month. Chronic care management billing fails far more often on the first six items than on the code selection.

This is the workflow guide. If you want the code level detail, our CPT 99490 requirements guide and the 99439 add on code guide cover the descriptors and the monthly service elements. What follows is the part that sits between the coordinator’s minutes and a paid remittance.

On this page

• What has to be true before you bill
• Seven steps to bill for chronic care management
• Which date of service belongs on the claim
• The place of service field, where common advice goes wrong
• A number in the CMS booklet that contradicts its own table
• What you cannot bill in the same month
• What the codes pay in 2026, and the unit limits
• What building a program of our own taught us about the claim side
• Frequently asked questions
• Where to take this next

What has to be true before you bill for chronic care management

Medicare treats chronic care management as a monthly bundle, not a procedure. That changes what a clean claim looks like. Nothing about the claim form itself is unusual, and the right to bill for chronic care management is not established by the form at all. The exposure lives in the record behind it, because every element CMS lists in the scope of service is something a reviewer can ask you to produce months later.

The eligibility test is two conditions expected to last at least 12 months or until death, which also place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline. Neither half of that test names a diagnosis, which surprises most practices. We covered the screening logic in detail in what conditions qualify for chronic care management, and the short version is that duration and risk both have to be visible in the chart, not merely inferable from a problem list.

Seven steps to bill for chronic care management

1. Hold the initiating visit, and actually discuss the program during it

CMS requires an initiating visit before services start for new patients and for anyone the billing practitioner has not seen in the previous year. It has to be a comprehensive evaluation and management visit, an annual wellness visit, or an initial preventive physical exam. The CMS billing FAQ is more specific than the booklet here: levels 2 through 5 office visits qualify, and so does the face to face visit inside transitional care management.

The trap is in the same FAQ. If the practitioner furnishes a qualifying visit but never discusses chronic care management at it, that visit cannot serve as the initiating visit. A practice can hold a perfectly good annual wellness visit in January, enroll the patient in February, and have no valid initiating visit at all.

2. Get consent, once, and store it somewhere a reviewer can reach

Consent may be verbal, a change CMS made in the CY 2017 fee schedule rule. It is obtained once, not monthly and not annually, and it has to be obtained again only if the patient moves to a different billing practitioner. What must be documented is a short list: that the service is available, that cost sharing may apply, that only one practitioner may bill it in a calendar month, that the patient can stop at the end of any month, and whether the patient accepted or declined.

One consequence is worth stating plainly. If consent was not obtained, you cannot bill Medicare and you cannot bill the patient either. CMS says an advance beneficiary notice is not appropriate here, because chronic care management is a covered service. Unconsented work is simply unbillable.

3. Build the electronic care plan before the month you bill

The care plan has to be electronic, patient centered, comprehensive, and available promptly inside and outside the practice. CMS calls its element list typical rather than mandatory, which practices sometimes read as permission to keep it thin. The safer reading is that the plan should reflect a real assessment across physical, mental, cognitive, psychosocial, functional, and environmental domains, and that anything missing should be missing for a documented clinical reason.

4. Capture minutes at the moment the work happens

For 99490 and 99439, the countable time is clinical staff time under general supervision, plus the billing practitioner’s own time if it is not being reported under 99491. General supervision means the practitioner does not have to be in the building. It does not mean the practitioner can step back entirely: the CMS FAQ states that oversight, management, collaboration, and reassessment by the billing practitioner cannot be delegated or subcontracted to anyone.

Two counting rules catch people out. Time that counts toward chronic care management cannot also count toward any other billed code, including an office visit on the same day. And when one activity benefits several patients, the minutes get split among them. The CMS FAQ gives the arithmetic directly: 30 minutes of work benefiting three patients is 10 minutes each, not 30 minutes each.

5. Confirm nobody else is billing the same patient this month

Only one practitioner may bill for chronic care management on behalf of a given patient in a given calendar month. There is no registry to check, which is why the consent script has to tell the patient this and why the enrollment conversation should ask whether another practice already offers the service. A specialist offering principal care management for a different condition is a separate matter and is allowed alongside chronic care management from the primary care practitioner, provided the two care plans are distinct.

6. Pick the code that matches whose time it was

The code follows the staffing, not the difficulty. Clinical staff time reports under 99490 with 99439 as the add on. Time the physician or other qualified professional spends personally reports under 99491 and 99437 instead, and clinical staff minutes never count toward those. Complex chronic care management sits in a third lane and additionally requires moderate to high complexity medical decision making by the practitioner during the service period.

7. Submit, then reconcile the month you just closed

The claim itself is ordinary. What is not ordinary is that the service period and the billing cycle are the same length, so a month that closes badly cannot be fixed by working harder next month. Build a monthly close step that reconciles enrolled patients against patients whose minutes crossed a threshold, and treat the gap between those two numbers as the metric that tells you whether the program is working.

Which date of service belongs on the claim

You have a choice, and most practices do not know it. For 99490, 99439, 99491, and 99437, CMS states that the practitioner may report the claim at the conclusion of the service period or may report it once the time threshold for the code is met, choosing that date as the date of service without holding the claim to month end. Complex chronic care management is different: because the decision making is judged across the whole period, those codes should be reported at the conclusion of the service period.

There is a condition attached to the early option. CMS expects services to continue through the rest of the month as medically necessary even after the threshold is met. Billing on day nine and going quiet on day ten is not what the policy contemplates.

In practice the choice is an operational one rather than a compliance one. Billing at threshold smooths cash and makes it obvious in real time which patients have crossed the line. Billing at month end gives you one reconciliation event and one place to catch errors. Whichever you choose, choose it once and apply it to every patient, because a mixed convention makes the month end reconciliation nearly impossible to read.

The place of service field, where common advice goes wrong

Search this topic and you will find guidance telling you to report place of service 11, the office. That is right for many practices and wrong as a rule. The CMS billing FAQ says chronic care management is priced in both facility and non facility settings, and that the billing practitioner should report the place of service for the location where they would ordinarily provide face to face care to that beneficiary.

That matters most for practices that see patients in skilled nursing facilities, nursing facilities, or assisted living. You may bill chronic care management for those patients, and the place of service should describe where you would ordinarily see them, not where the coordinator was sitting when she made the call. Since the facility and non facility rates differ, a default of 11 applied across a mixed panel is a payment accuracy problem in both directions.

A number in the CMS booklet that contradicts its own table

Here is something you will only find by reading the source rather than a summary of it. On page 3 of the CMS booklet Chronic Care Management Services (MLN909188, June 2025), the highlights section says the service elements apply to both non complex chronic care management, in parentheses “at least 30 minutes per month,” and complex chronic care management at least 60 minutes per month.

Thirty minutes is not the non complex threshold. Two pages later the same booklet says eligible practitioners may bill at least 20 minutes or more per month, and Table 2 on page 10 lists 99490 as the first 20 minutes of clinical staff time. The CMS billing FAQ says 20 minutes as well. The parenthetical on page 3 is the outlier.

Bill to the code descriptor, which is 20 minutes for 99490. The reason to know about the discrepancy is not that it changes the threshold. It is that a reviewer, an auditor, or a new coordinator reading page 3 of the current CMS booklet can arrive at a sincere and wrong belief about your program, and the fastest way to close that conversation is to be able to point at Table 2 in the same document.

What you cannot bill in the same month

The concurrency rules are where otherwise clean claims get denied. From the June 2025 CMS booklet:

• Non complex and complex chronic care management cannot both be reported for the same patient in a calendar month, and 99491 or 99437 cannot be reported in the same month as 99487, 99489, 99490, or 99439.
• Home health care supervision (G0181), hospice care supervision (G0182), and certain end stage renal disease services (90951 through 90970) block chronic care management for the same service period.
• Complex chronic care management and prolonged evaluation and management services cannot be reported in the same calendar month.
• Transitional care management is allowed alongside chronic care management, but the same minutes cannot be counted twice.
• You may bill either remote physiologic monitoring or remote therapeutic monitoring concurrently with chronic care management, but not both.

If your denials in this category are growing, the fix is usually an edit at the front of the billing workflow rather than an appeal at the back of it. The same logic we set out in our guide to reducing claim denials applies here: a rule that can be checked before submission should never be discovered on a remittance.

What the codes pay in 2026, and the unit limits

These are 2026 national non facility amounts, calculated from the CMS Physician Fee Schedule relative value file released in July 2026 at the nonqualifying APM conversion factor of $33.4009, and they are not adjusted for your locality.

The unit limits come from the CMS medically unlikely edits table for practitioners effective 1 July 2026, and they are the practical ceiling most practices never think about. With 99439 capped at two units, the most clinical staff time you can report in a month is 60 minutes, paying $167.01 in total at national rates. Minute 61 onward is unbillable under this code family, which is exactly the point at which a genuinely complex patient should have been evaluated for complex chronic care management instead.

To turn those rates into a number for your own panel, our care management revenue calculator does the arithmetic against panel size and staffing rather than against a national average.

What building a program of our own taught us about the claim side

We are not writing this from the outside. Our team designed, implemented, and continues to support a care management program at the musculoskeletal and regenerative medicine clinic our group operates. That program runs remote therapeutic monitoring and principal care management rather than chronic care management, because that is what the patient panel supports, and the clinic’s own employees run it day to day. Being specific about that seems more useful than implying broader experience than we have.

The lesson that transferred hardest was about the handoff, not the rules. In most practices the person capturing minutes and the person submitting claims are two different people who never speak, and the month boundary is the only thing that forces them to. Everything that goes wrong in a care management program shows up at that seam: minutes logged after the month closed, patients enrolled but never worked, a coordinator who assumed the biller would catch the eligibility lapse and a biller who assumed the coordinator already had.

So the first artifact we build for any practice is not a workflow diagram. It is a monthly close checklist with a named owner, which lists enrolled patients, minutes captured, thresholds crossed, claims submitted, and the difference between the second and the fourth. The programs that hold up over a year are the ones where somebody reads that list every month and has to explain the gap out loud.

One more thing worth saying about how we work. We charge flat fees set in advance for care management implementation, never a per patient fee and never a percentage of collections. We design, build, and support the program. We do not run it, and we do not submit claims.

Frequently asked questions

Can we bill for chronic care management if the patient dies mid month?

Yes. The CMS billing FAQ states the codes may be billed if the beneficiary dies during the service period, provided the required time for the code was met that calendar month and all other billing requirements are satisfied.

Does the patient owe anything for chronic care management?

Standard Part B cost sharing applies. Medigap policies cover it in the normal way, and for Qualified Medicare Beneficiaries, Medicaid is responsible for the cost sharing. CMS notes that many states pay little or none of it in practice, which is a real consideration when you plan enrollment conversations for a dual eligible population.

Can an outside company do the clinical staff work?

For chronic care management, yes, if the incident to and other billing rules are met. CMS has said that where there is little oversight by the billing practitioner or a lack of clinical integration with the third party, the service is not actually being furnished and should not be billed. Separately, the work cannot be performed by anyone located outside the United States. Our comparison of chronic care management companies walks through what to ask before signing.

Does the proposed 2027 staffing rule change chronic care management billing?

No. The CMS proposal on employee only staffing covers remote physiologic monitoring and remote therapeutic monitoring, and it is a proposed rule that has not been finalized. Chronic care management and principal care management are not within its scope as proposed. We explain what it does and does not reach in our breakdown of the proposal.

Do we need certified EHR technology to bill for chronic care management?

You must record demographics, problems, medications, and medication allergies in a structured format using EHR technology certified to the criteria acceptable as of 31 December of the year before the payment year. CMS has confirmed that technology losing its certification mid year can still be used for that payment year.

Where to take this next

If you are deciding whether the program is worth starting, begin with what chronic care management is and what Medicare is buying, then screen your panel against the eligibility test. If you have already decided and are building the workflow, the seven steps above are the order to build them in, and the monthly close checklist is the piece to write first rather than last. Most practices that struggle to bill for chronic care management consistently are not missing a rule, they are missing that one recurring meeting.

Practice Management Consultancy designs and implements care management programs that a practice’s own staff runs, from eligibility analysis through the first billing cycles, on a flat fee set in advance. Start with a care management assessment, or get in touch with a question about your own panel.

Sources

• CMS, Chronic Care Management Services, MLN909188 (June 2025)
• CMS Division of Practitioner Services, Frequently Asked Questions About Practitioner Billing for Chronic Care Management Services (last updated 16 August 2022)
• CMS Physician Fee Schedule Relative Value File, July 2026 release (rates are 2026 national non facility amounts at the nonqualifying APM conversion factor of $33.4009, before locality adjustment)
• CMS NCCI Medically Unlikely Edits, practitioner table effective 07/01/2026

CPT is a registered trademark of the American Medical Association. Code descriptions here are plain language summaries, not the official CPT descriptors. This article is general information about Medicare billing policy and is not legal, coding, or compliance advice for a specific practice.

Disclosure: our team operates and manages the medical practice referenced in first-person examples on this site.