2026 Billing Workflow Matrix

APCM + Behavioral Health + RPM/RTM

Quick reference for practice leaders and billers. Use this table at month-end before claims go out. Sources: CMS APCM page, CY 2026 PFS Final Rule Fact Sheet, and MLN Telehealth and RPM guidance.

Scenario	Allowed?	Codes Involved	Evidence Required	Pre-Claim Gotchas
1. APCM alone	Yes	G0556 / G0557 / G0558	Consent and initiating-visit logic documented 24/7 access and continuity with designated clinician/team Care plan updated this month (problems/goals, meds, transitions, population management)	Only one APCM base code per patient per month Make sure APCM documentation stands alone in an audit
2. APCM + BH add-on	Yes (with conditions)	APCM base (G0556/57/58) + BH add-on (G0568/G0569/G0570)	Same practitioner bills APCM and BH add-on in the same month CoCM/BHI-like activities documented (screenings, care-manager notes, case review, outcomes) BH work clearly tied to the APCM billing month	Do not bill BH add-on without APCM base in the same month Do not use different practitioners for APCM and BH add-on Do not double-bill legacy CoCM/BHI for the same patient/month
3. APCM + RPM	Yes (parallel)	APCM base + RPM device and management codes	APCM criteria met RPM medical necessity documented (diagnosis and rationale) Correct day bucket (2-15 vs 16-30) and time bucket (10-19 vs 20+) RPM evidence (days/time/actions) documented separately from APCM	One RPM billing practitioner per patient / 30-day period Do not reuse APCM coordination time as RPM management time Ensure selected RPM CPT matches documented days/time
4. APCM + RTM	Yes (parallel)	APCM base + RTM device and management codes	APCM evidence present RTM medical necessity documented for therapeutic/non-physiologic data RTM days/time consistent with selected RTM CPT	Do not bill RTM and RPM together Keep RTM evidence separate from APCM documentation Validate supervision and incident-to requirements
5. APCM + BH add-on + RPM	Yes (highest complexity)	APCM base + BH add-on + RPM device/management codes	All APCM requirements satisfied BH add-on work documented per add-on rules RPM evidence documented per day/time requirements APCM, BH, and RPM documentation streams are clearly separated	Enforce same-practitioner rule for APCM + BH add-on Enforce RPM practitioner exclusivity Prevent double counting APCM/BH work as RPM time
6. RPM or RTM only (no APCM)	Yes	RPM or RTM device and management codes	Established-patient and medical-necessity documentation Device assignment, day counts, management time, and actions documented For RTM, therapy-oriented self-reported data stream is in place	One RPM practitioner per 30-day period No RPM + RTM pairing Do not reuse work that is already billed under another program
7. BH add-on without APCM (or with different practitioner)	No	BH add-on billed without APCM base, or by a different practitioner	BH documentation exists but APCM base is absent that month, or BH add-on is billed by someone other than the APCM practitioner	Treat as do-not-bill/high-risk scenario Correct by adding valid APCM base under same practitioner or remove BH add-on Validator should hard-fail this configuration

This matrix is a planning aid. Confirm current CMS/MLN guidance and your MAC edits before billing.

FairPath is designed to handle this complexity for you.

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This allows you to scale your own program without losing quality, breaking trust with physicians, or losing control of your revenue. We provide the precision of an automated medical director without the chaos.

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2026 Billing Workflow Matrix

APCM + Behavioral Health + RPM/RTM

FairPath is designed to handle this complexity for you.

Standard Operating Procedures

RPM Manual

RTM Guide

CCM Guide

APCM Playbook