
- More than 150 organizations joined the CMS ACCESS Model in July 2026.
- Payers covering more than 165 million people pledged ACCESS-aligned payments by 2028.
- Medicare chronic care management requires two or more chronic conditions lasting 12+ months.
- CPT 99490 covers the first 20 minutes of clinical staff CCM time per month.
- New 2026 RPM codes 99445 and 99470 cover 2–15 days of data and 10 minutes of management.
- 36% of adults with three or more conditions skipped or delayed care because of cost.
TL;DR
With payers covering more than 165 million people pledging ACCESS-aligned payments by 2028, digitally-enabled chronic care is becoming a financial opportunity as much as a clinical one. Start by confirming Medicare eligibility, then build your technology, staffing, and documentation workflows so you can bill for the between-visit work your team already does and track ROI from day one.
Chronic care management (CCM) is becoming increasingly digital—and Medicare policy is helping accelerate the shift. In July 2026, more than 150 healthcare organizations began participating in the CMS Innovation Center’s Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model, which emphasizes the use of technology to improve outcomes for patients with common chronic conditions.
The model reflects a broader CMS push toward digitally-enabled chronic care, including remote monitoring, digital care management platforms, and data-driven approaches that help providers identify needs and engage patients beyond the walls of the practice. For practices, the message is clear: Technology is becoming an increasingly important part of how chronic care is coordinated, delivered, and measured. Building a digitally-enabled chronic care management program now can help practices strengthen care between visits, improve efficiency, and prepare for a healthcare environment that increasingly rewards continuous, connected chronic care.
What is digitally-enabled chronic care?
Digitally-enabled chronic care uses technology and health data to help care teams continuously monitor, engage, and coordinate care for patients with chronic conditions — both during and between office visits. This enables earlier and more proactive intervention. In contrast, in a traditional model, chronic care tends to revolve around scheduled, in-person encounters, with relatively limited visibility into what happens to the patient between visits. Clinicians often rely on information collected during appointments, and patients may need to initiate contact when symptoms worsen or questions arise.
| Traditional chronic care | Digitally-enabled chronic care |
|---|---|
| Episodic: Care centers primarily around scheduled office visits. | Continuous: Digital tools help extend care between scheduled visits. |
| Reactive: Patients often contact the practice when a problem or symptom arises. | Proactive: Care teams can identify changes and intervene earlier. |
| Point-in-time data: Clinicians rely heavily on information collected during visits. | Ongoing data: Remote monitoring and other technologies can provide information about patients between visits. |
| In-person dependent: Many interactions require an office visit or phone call. | Multiple ways to connect: Portals, messaging, telehealth, and other digital tools facilitate ongoing communication. |
| Limited visibility between visits: Practices may not know a patient's condition is worsening until the patient reaches out or returns. | Greater visibility between visits: Remote monitoring and patient-reported information can help flag potential concerns sooner. |
| More manual coordination: Staff may rely on phone calls, faxes, and manual follow-up. | Technology-supported coordination: Digital care management platforms and integrated workflows can streamline follow-up and information sharing. |
| Individual patient focus: Care management often occurs one patient at a time as needs arise. | Population-level management: Analytics can help practices identify and prioritize patients who may need additional support. |
| Care happens primarily within the practice: The office visit is the central touchpoint. | Care extends into patients' daily lives: Technology helps patients manage their conditions at home while remaining connected to their care team. |
Keep in mind: For many practices, digitally-enabled chronic care doesn't replace traditional chronic care — it fills the gaps between in-person encounters. A patient might still see their physician regularly in the office while digital tools help the care team monitor their condition, communicate with them, coordinate services, and respond to emerging needs between visits.
Why digitally-enabled chronic care matters for practices now
Digitally-enabled chronic care matters for practices now because the way chronic conditions are managed — and increasingly paid for — is shifting from episodic, visit-based care toward continuous, technology-supported care focused on measurable outcomes. Practices that don't have the infrastructure and workflows to support ongoing chronic care may not only miss opportunities to improve patient outcomes but also leave revenue on the table. By identifying eligible patients, capturing reimbursable care management activities, and preparing for emerging value-based payment models, practices can turn chronic care management into both a clinical and financial opportunity.
CMS ACCESS Model 2026
The CMS ACCESS Model is a particularly visible sign of the shift toward digitally-enabled chronic care. Launched in July 2026, ACCESS tests recurring, outcome-aligned payments for technology-supported chronic care and is specifically designed to complement traditional physician care. CMS also recently expanded the model with additional chronic-condition tracks beginning in 2027. In addition, payers representing more than 165 million people across Medicare Advantage, Medicaid, and commercial insurance have pledged to offer payment arrangements aligned with core ACCESS principles by 2028.
As CMS and other payers place greater emphasis on technology-supported, outcomes-based care, practices that build the right technology, workflows, and care coordination processes now may be better positioned to keep patients connected between visits and adapt to emerging value-based payment opportunities.
Patient access
Patients with multiple or complex conditions struggle to access the ongoing care they need. A 2026 KFF survey found that 36% of adults ages 18–64 with three or more health conditions skipped or delayed care because of cost, while 25% could not find a provider with available appointments. Among those who postponed care, 27% said their health worsened as a result. By extending chronic care beyond the office through remote monitoring, virtual communication, and other digital tools, practices have an opportunity to maintain stronger connections with patients, identify needs earlier, and potentially address some barriers to timely care. In addition, stronger between-visit engagement may also improve care plan adherence and patient retention while helping practices succeed under value-based arrangements that increasingly reward outcomes and ongoing chronic disease management.
Step 1: Confirm eligibility and Medicare requirements
Adding digital tools does not change the underlying rules for billing Medicare for chronic care management. Before enrolling patients, practices need to verify that they meet the applicable eligibility criteria and understand billing requirements.
Which patients qualify
Eligible CCM patients have multiple (2 or more) chronic conditions expected to last at least 12 months or until the patient’s death or that place them at significant risk of death, acute exacerbation or decompensation, or functional decline.
Use EHR data to create a preliminary list of patients who may qualify for Medicare CCM, rather than identifying them manually during individual visits. Consider these steps:
- Query the EHR for Medicare patients with two or more chronic conditions.
- Identify patients whose conditions are expected to persist and put them at significant risk of deterioration. This information in the EHR can help: Condition duration, recent hospitalizations or ED visits, medication burden, functional limitations, and utilization patterns
- Flag these patients for clinical review to confirm whether they ultimately meet chronic care management Medicare guidelines.
Consent and enrollment requirements
Before providing and billing for digitally-enabled chronic care, the practice must obtain the patient’s written or verbal consent and document it in the medical record. For patient consent, practices must inform the patient of the following and document same in their medical record:
- Availability of CCM services
- Possible cost-sharing responsibilities
- Only one practitioner can provide and bill CCM services during a calendar month
- Right to stop CCM services at any time (effective at the end of the calendar month)
- Whether the patient accepted or declined services
For new patients or patients who have not been seen by the billing practitioner within the prior year, CMS also requires an initiating visit before CCM begins. That visit can occur as part of a comprehensive E/M service, Annual Wellness Visit, or Initial Preventive Physical Exam.
Documentation needed to support medical necessity
Documentation to support medical necessity must include patient consent as well as electronic recording of patient health information (i.e., the patient’s demographics, problems, medications, and medication allergies), comprehensive care plan, and medical decision making. Note that complex CCM services require and include moderate- to high-complexity medical decision-making by the physician or other billing practitioner.
Remember: diagnosis codes alone don't tell the whole story. Instead, ensure documentation includes the following:
- Why the patient’s chronic conditions require ongoing monitoring, care coordination, and management, including the need for monitoring, coordination, and management in between office visits
- Conditions being managed, relevant clinical and functional risks, treatment goals, medication management needs, planned interventions, and coordination with other clinicians
- Relevant information from remote monitoring, patient messaging, digital check-ins, and other technologies to show how the care team is managing the patient over time
- How the care team responds to this information (e.g., adjusting the care plan, addressing medication concerns, coordinating follow-up, or escalating a change in the patient's condition)
Step 2: Choose your technology stack
Choosing a tech stack means identifying the combination of tools needed to support digitally-enabled chronic care, such as the EHR, care management platform, remote monitoring technology, patient communication tools, and analytics. Practices should prioritize solutions that integrate with existing systems, support efficient workflows and data sharing, protect patient information, and give care teams actionable data without adding unnecessary administrative burden.
EHR integration bidirectional RPM data flow
When evaluating EHR integration for a digitally-enabled chronic care management program, practices should look for bidirectional interoperability that allows RPM data to flow into the EHR while relevant clinical and demographic data flows back to the RPM platform. Also look for real-time or timely data exchange, configurable alerts and thresholds, integration into existing clinician workflows, automated documentation, and the ability to distinguish actionable information from data that could contribute to alert fatigue.
Choosing RPM devices and vendors
When choosing RPM devices and vendors, look for clinically appropriate, easy-to-use devices that reliably capture and transmit accurate patient data with minimal burden on patients and staff. Evaluate whether the vendor:
- Integrates with your EHR
- Meets applicable privacy and security requirements
- Provides customizable alerts and dashboards
- Supports bidirectional data exchange
Also consider patient support and training, device connectivity, workflow fit, scalability, vendor responsiveness, and total cost as the program grows.
Evaluating CCM/RPM software (build vs. buy)
When deciding whether to build or buy chronic care management software, consider upfront and ongoing costs, implementation time, EHR integration, customization needs, scalability, security, compliance, and available IT resources. The same is true when deciding whether to build or buy remote patient monitoring software; however, practices must also consider device compatibility, bidirectional data exchange, alert management, and patient usability. In general, building offers greater control but requires more technical expertise and maintenance, while buying can accelerate deployment and provide ongoing vendor support but may offer less flexibility and involve recurring fees.
Something to consider: The best chronic care management software complements the EHR by adding specialized tools for patient enrollment, care-management workflows, and population-level monitoring.
Up front technology costs
For a digitally-enabled chronic care management program, upfront technology costs may include a care management platform, RPM devices, EHR integration, patient communication tools, analytics capabilities, and the infrastructure needed to securely exchange and manage patient data. Practices should also budget for implementation, configuration, device provisioning, staff training, workflow redesign, and patient onboarding, not just the price of the technology itself.
Step 3: Design your staffing and escalation model
A clear staffing and escalation model ensures the right team members monitor patient data, perform CCM activities, respond to alerts, and escalate clinical concerns to the appropriate clinician at the right time. Defining these responsibilities upfront helps:
- Ensure digital tools generate timely action rather than simply more data
- Prevent gaps in care
- Reduce alert fatigue
- Support efficient workflows
Team-based role for digitally-enabled chronic care programs
A digitally-enabled chronic care management program works best when each care team member has a clearly defined role across the entire patient journey, not just when an abnormal reading occurs. Define responsibilities based on applicable Medicare supervision and billing requirements, state scope-of-practice rules, and the practice's staffing model.
| Team member role | Potential responsibilities in digitally-enabled chronic care management |
|---|---|
| Physician/NP/PA | Provides clinical oversight, confirms appropriateness of CCM, establishes treatment goals, makes clinical decisions, and manages escalated concerns. |
| RN/LPN | Conducts clinical outreach, reviews patient status and relevant digital/RPM data, reinforces the care plan, supports medication management, and triages concerns. |
| Care coordinator | Coordinates services and referrals, follows up with patients, tracks care-plan activities, identifies gaps in care, and helps patients navigate services. |
| Medical assistant | Supports enrollment, patient onboarding, routine outreach, device setup, data collection, and other tasks permitted within scope and practice protocols. |
| Billing/RCM staff | Verifies coverage, tracks documentation and time requirements, assigns appropriate codes, submits claims, and monitors denials and reimbursement. |
| Program manager/clinical leader | Oversees workflows, staffing, technology performance, quality measures, patient engagement, compliance, and overall program performance. |
For smaller practices, one person may fill several of these roles. The important step is to define who owns enrollment, care planning, routine outreach, monitoring, documentation, billing, and escalation—and build those responsibilities into the digital workflow so tasks don't fall through the cracks.
Abnormal readings: Thresholds and escalation protocols
When setting escalation thresholds for abnormal readings, practices should avoid a one-size-fits-all approach.
| Consideration | What to define | Why it matters |
|---|---|---|
| Patient-specific parameters | Consider the patient's condition, baseline readings, care plan, and individual risk factors when establishing thresholds. | Helps ensure alerts reflect meaningful changes for that patient rather than relying solely on one-size-fits-all cutoffs. |
| Severity of abnormal readings | Establish different thresholds for mildly abnormal, significantly abnormal, and potentially urgent readings. | Allows the practice to match the response to the level of clinical concern. |
| Persistence and trends | Determine whether a single abnormal reading or a pattern of abnormal readings should trigger action. | Helps distinguish potentially meaningful trends from isolated readings. |
| Escalation pathway | Specify when staff should repeat a reading, contact the patient, escalate to a clinician, or direct the patient to urgent or emergency care. | Gives staff a consistent response protocol. |
| Alert ownership | Identify which team member receives and reviews each type of alert. | Prevents alerts from going unnoticed or being assumed to be someone else's responsibility. |
| Response times | Set expectations for how quickly different levels of alerts should be reviewed and addressed. | Helps ensure higher-risk findings receive timely attention. |
| After-hours coverage | Establish what happens when an abnormal reading occurs outside normal practice hours and communicate this to patients. | Prevents patients from assuming RPM is continuously monitored when it is not. |
| Documentation | Define how alerts, patient outreach, clinical decisions, and follow-up actions are recorded. | Creates a clear record of how the care team responded to incoming data. |
| Ongoing refinement | Monitor alert volume, false alarms, escalations, and outcomes and adjust thresholds when appropriate. | Helps reduce alert fatigue while preserving clinically meaningful alerts. |
In addition, practices should establish role-based escalation protocols before monitoring begins.
| Alert/action level | Potential care team role | Responsibility |
|---|---|---|
| Routine monitoring | MA, care coordinator, nurse, or other designated staff | Review incoming data, identify missing readings, conduct routine outreach, and follow established protocols. |
| Abnormal reading requiring follow-up | Nurse or appropriately trained clinical staff | Contact the patient, verify the reading, assess relevant symptoms, document findings, and determine whether escalation criteria are met. |
| Clinical escalation | Physician, NP, PA, or other qualified practitioner | Evaluate concerning readings or trends and determine whether changes to treatment, medications, monitoring, or follow-up are needed. |
| Urgent/emergent concern | Qualified clinical staff following established protocol | Escalate immediately according to the practice's emergency protocol and direct the patient to the appropriate level of care when indicated. |
| Ongoing oversight | Physician/clinical leader and program manager | Review alert patterns, response times, outcomes, staffing needs, and thresholds to identify opportunities to improve the program. |
Staffing and time constraints
Assess staff capacity, skill mix, and the time required for each activity before determining how responsibilities will be distributed. Technology can help ease that burden by automating routine tasks, prioritizing patients who need attention, streamlining documentation, and bringing actionable information into existing workflows. However, practices still need adequate staff to engage patients, review information, and respond when clinical intervention is needed.
Also keep in mind that CCM requires practices to provide patients with 24/7 access to a physician, other qualified practitioner, or clinical staff for urgent chronic care needs. Practices must also designate a care team member who maintains regular contact with the patient and is available for routine appointments. Patients and caregivers should have multiple ways to communicate with the care team, including phone, secure messaging, and a patient portal.
Step 4: Capture time, documentation, and billing
Accurately capturing time, documentation, and billing is essential to ensuring the work performed through a CCM program translates into compliant reimbursement — and the right EHR can help.
CPT 99490 / Medicare CCM billing
CPT code 99490 denotes the first 20 minutes per calendar month of CCM services provided by clinical staff under practitioner supervision. However, there are also a variety of other CCM codes to consider.
| Care management service | Code(s) | What it covers / key distinction |
|---|---|---|
| Chronic Care Management (CCM) — clinical staff | 99490 | First 20 minutes per calendar month of CCM services provided by clinical staff under practitioner supervision. |
| +99439 | Each additional 20 minutes of clinical staff CCM time. | |
| CCM — practitioner | 99491 | First 30 minutes per calendar month personally provided by the physician or other qualified healthcare professional. |
| +99437 | Each additional 30 minutes personally provided by the billing practitioner. | |
| Complex CCM | 99487 | First 60 minutes of clinical staff time; requires moderate- or high-complexity medical decision-making by the billing practitioner. |
| +99489 | Each additional 30 minutes of clinical staff complex CCM time. | |
| Comprehensive assessment and care planning | G0506 | Extensive assessment and care planning personally performed by the billing practitioner beyond the usual effort of the CCM initiating visit and CCM services. May be billed once, as part of the initiating visit. |
| Chronic Pain Management | G3002 | First 30 minutes of chronic pain management and treatment by a physician or other qualified healthcare professional. |
| +G3003 | Each additional 15 minutes. | |
| Advanced Primary Care Management (APCM) | G0556 | Level 1: patients with 0 or 1 chronic condition. |
| G0557 | Level 2: patients with 2 or more chronic conditions. | |
| G0558 | Level 3: patients with 2 or more chronic conditions and Qualified Medicare Beneficiary status. | |
| Principal Care Management (PCM) | 99424, 99425, 99426, 99427 | Monthly care management focused on a single high-risk chronic condition expected to last at least 3 months. |
| Principal Illness Navigation (PIN) | G0023, G0024, G0140, G0146 | Navigation for a serious, high-risk condition following an initiating E/M visit. G0140 and G0146 address navigation for behavioral health conditions by qualifying auxiliary personnel. |
| Community Health Integration (CHI) | G0019, G0022 | Services addressing unmet social needs that interfere with diagnosis or treatment and connecting patients with clinical and social resources. |
| Transitional Care Management (TCM) | 99495, 99496 | Coordinated care during the 30-day period following discharge from an inpatient setting back to the community. |
RPM billing codes and the 16-day data requirement
Remote patient monitoring (RPM) is one of the core technologies behind digitally-enabled chronic care. It provides physiologic data from connected medical devices, giving care teams greater visibility into a patient's condition between visits. When integrated into a digitally-enabled chronic care program, RPM data can help teams identify concerning trends, prioritize outreach, intervene earlier, and make more informed care-management decisions.
Historically, Medicare required at least 16 days of data in a 30-day period to bill RPM; however, beginning in 2026, new RPM coding accommodates shorter-duration monitoring periods.
| RPM code | What it covers | 2026 requirement |
|---|---|---|
| 99453 | Initial RPM device setup and patient education | Used for initial setup and education on use of the monitoring equipment. |
| 99445 — NEW for 2026 | RPM device supply and transmission of physiologic data | 2–15 days of data collection/transmission during a 30-day period. |
| 99454 | RPM device supply and transmission of physiologic data | 16–30 days of data collection/transmission during a 30-day period. |
| 99470 — NEW for 2026 | RPM treatment-management services | First 10 minutes of treatment-management time in a calendar month. |
| 99457 | RPM treatment-management services | First 20 minutes in a calendar month, including required interactive communication with the patient/caregiver. |
| 99458 | Additional RPM treatment-management services | Each additional 20 minutes of treatment-management time. |
| 99091 | Collection and interpretation of physiologic data by a physician or other qualified healthcare professional | 30 minutes of practitioner time during a 30-day period. |
| 99474 | Self-measured blood pressure monitoring | Review of patient-reported BP measurements and communication of a treatment plan; distinct from connected-device RPM. |
Avoiding common documentation gaps that trigger denials or audits
The biggest documentation risk in digitally-enabled chronic care is treating digital activity as documentation in itself. A stream of readings, alerts, messages, or timestamps doesn't necessarily demonstrate a billable service; practices need to document what the care team did with that information and how it supported the patient's ongoing care. Here are some additional documentation gaps that can trigger denials or audits and how the right EHR and billing software can help.
| Top documentation gap | Why it matters | How the right EHR and billing software can help |
|---|---|---|
| 1. Insufficient time documentation | CCM and many RPM services are time-based. Practices need to capture qualifying time, who performed the service, and which service the time supports. | Automate or simplify time tracking, associate time with the appropriate patient and service, and alert staff when monthly billing thresholds are reached. |
| 2. Digital activity isn't tied to care management | An RPM reading, portal message, or alert alone doesn't demonstrate care management. The record should show how the care team used the information to manage the patient's care. | Integrate RPM data, messages, alerts, and care-management documentation into the clinical workflow, making it easier to document the action taken in response. |
| 3. RPM requirements aren't documented | Documentation must support the requirements of the RPM code billed, including applicable device/data requirements, treatment-management time, and patient interaction. | Track device data and monitoring days, treatment-management time, and patient interactions and connect those elements with the documentation needed to support billing. |
| 4. Duplicate time or services | CCM and RPM can be provided to the same patient, but practices should not count the same time or work toward multiple separately billed services. | Separate CCM and RPM activities and time and use billing edits or alerts to help identify potential duplicate or incompatible billing before claims are submitted. |
| 5. Care plan doesn't reflect digital care | The care plan should show how remote monitoring, digital communication, and other technology support the patient's goals, interventions, monitoring, and follow-up. | Bring digital information into the care plan and make it accessible across the care team, allowing staff to update goals, interventions, and follow-up as the patient's needs change. |
Step 5: Measure outcomes and ROI
Once a digitally-enabled chronic care program is up and running, practices need to determine whether it is financially sustainable, clinically effective, and valuable to patients and payers.
Calculating CCM ROI / breakeven per enrolled patient
To calculate breakeven per enrolled patient, practices should determine the average monthly revenue generated per patient and compare it with the per-patient cost of technology, devices, staff time, vendor fees, and other program expenses. They can then calculate how many enrolled—and actively participating—patients are needed for program revenue to cover total fixed and variable costs.
Clinical outcome metrics to track
Practices should select clinical outcome metrics that align with the chronic conditions they manage, such as blood pressure or glucose control, medication adherence, symptom improvement, hospitalizations, and emergency department visits. Track these measures over time and compare them with baseline data to determine whether digitally-enabled care is improving patient outcomes and identify opportunities for intervention.
Reporting outcomes for value-based contracts
Practices should identify the quality, utilization, cost, and patient outcome measures tied to each value-based contract and build workflows to capture those data consistently. Use dashboards or reports to track performance against contract benchmarks and demonstrate how digitally-enabled chronic care affects outcomes such as:
- Disease control
- Emergency department use
- Hospitalizations
- Total cost of care
For example, if a value-based contract rewards improved hypertension control and reduced hospital utilization, the practice could report the percentage of enrolled patients whose blood pressure reached the target range, along with changes in ED visits and hospitalizations. The practice could then compare results before and after enrollment to demonstrate whether digitally-enabled chronic care is contributing to the contract's quality and utilization goals.
Patient adoption and digital literacy
Practices should track whether patients enroll, consistently use digital tools or connected devices, transmit required data, and respond to digital outreach, while identifying barriers such as limited technology skills, connectivity, language, or difficulty using devices. Provide simple onboarding, hands-on education, technical support, and alternative ways to participate when appropriate so digital literacy does not become a barrier to effective chronic care.
Frequently asked questions
- Operationally: enrollment rate, patient retention, and consistent monthly documentation.
- Clinically: improvements in measures like blood pressure or A1C, and fewer avoidable ER visits or readmissions.
- Financially: reimbursement captured versus program cost, and time-to-breakeven.
You’re already coordinating care between visits. The question is whether your EHR captures it. Take Tebra’s self-guided product tour to see how EHR+ tracks care-coordination time, supports your documentation, and carries it through to billing in one system.





