ACCESS Co-Management Payment (CMP) Billing Guidance

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The Co-Management Payment (CMP) compensates eligible Medicare Part B practitioners for reviewing ACCESS care updates and performing related care coordination activities for people enrolled in an ACCESS track. Cost-sharing does not apply for CMP services.

Who Can Bill?

The following Medicare Part B-enrolled practitioner types are eligible to bill CMP HCPCS codes beginning July 5, 2026:

• All Physicians
• Nurse Practitioners
• Physician Assistants
• Certified Clinical Nurse Specialists
• Clinical Psychologists / Psychologists Billing Independently
• Licensed Clinical Social Workers
• Registered Dietitians / Nutrition Professionals
• Physical Therapists in Private Practice
• Occupational Therapists in Private Practice
• Speech Language Pathologists in Private Practice
• Marriage and Family Therapists
• Mental Health Counselors

The following will also be eligible:

• Federally Qualified Health Centers (FQHCs) – beginning October 1, 2026
• Rural Health Clinics (RHCs) – beginning October 1, 2026
• Pharmacies (Specialty Code A5) – beginning October 1, 2026

What Qualifies for a CMP

To bill a CMP, the eligible practitioner must:

1. Review an ACCESS Care Update for that beneficiary and track
2. Perform at least one care coordination activity, such as: 
   • Adjusting or reconciling medications
   • Updating the problem list
   • Establishing or modifying monitoring or follow-up instructions
   • Coordinating care among clinicians involved in the beneficiary’s care
   • Communicating with the ACCESS health care provider
   • Documenting clinical agreement or disagreement with ACCESS recommendations, including rationale.

A minimum of 5 minutes total of practitioner time is required for review and associated care-coordination activity.

Payment Amounts and HCPCS Codes

CMS pays 100% of the Medicare-allowed amount, subject to 2% sequestration reduction established by the Budget Control Act of 2011, Pub. L. No. 112-25, § 302, 125 Stat. 240 (2011). Actual payments vary by location based on the Medicare Physician Fee Schedule Geographic Adjustment Factor (GAF).

Beneficiary cost-sharing does not apply to the CMP, and consequently, practitioners do not need to obtain beneficiary consent in advance of providing CMP services.

*Onboarding support and device/application setup may include one or more of:

• Supporting the beneficiary in identifying an appropriate ACCESS health care provider for their needs;
• Supporting enrollment with the ACCESS health care provider;
• Educating the beneficiary on the ACCESS health care provider’s role;
• Assisting with device, application, or data-sharing setup; or
• Confirming successful initiation of data transmission or engagement.

Payment Frequency

• Payable up to 3 times every 12 months, per beneficiary, per ACCESS track
• Clinicians may bill CMPs for multiple ACCESS tracks for the same beneficiary when distinct review and care-coordination activities are performed for each track
• Modifier AC for onboarding support may be billed only once per billing provider, per beneficiary, per ACCESS track

Claim Submission Requirements

For more information, see CMS-1500 Form and Chapter 26 of the Medicare Claims Processing Manual for general Medicare Part B billing guidelines.

Go to CMP Billing Guidelines for FQHCs and RCHs

Beneficiary Identification (Item 1a. Insured’s ID Number)

• The beneficiary’s Medicare Beneficiary Identifier (MBI) must be reported on the claim.

Referring Practitioner (Item 17. Name of Referring Provider or Other Source)

• The referring practitioner may be optionally reported on the claim. 

Diagnosis Code (Item 21. Diagnosis or Nature of Illness or Injury)

• At least one of the diagnosis codes on the billed claim must correspond to one of the qualifying conditions for the applicable ACCESS track, as specified under Section 3.0.2.4 Value Sets of the Artifacts Page of the ACCESS Model API Implementation Guide.
• Claims will be denied if a corresponding diagnosis code is not included.

Date (Item 24.A.) and Place of Service (Item 24.B.)

• Date of Service (DOS): The DOS must correspond to the date on which the documented review or care-coordination activity occurred. CMP claims must be submitted within standard Medicare timely filing limits.
• Place of Service (POS): The POS must reflect the practice setting of the rendering practitioner, as appropriate.

Procedure Codes (Item 24.D Procedures, Services, or Supplies)

• The G-code corresponding to the beneficiary's ACCESS track must be reported on the clam, as specified in the Payment Accounts and HPCS Codes table in the CMP billing guidelines.
• If applicable, the AC modifier should be  reported with the HPCS code.

Service Units (Item 24.G. Days or Units)

• One unit must be reported per claim line for ACCESS CMP services.

Practitioner National Provider Identifier (NPI) (Item 24.J. Rendering Provider ID)

• The rendering practitioner’s Type 1 Indivitual NPI must be reported on the claim. This NPI will be validated to confirm that it is active in National Plan and Provider Enumeration System (NPPES), enrolled in Medicare via Provider Enrollment, Chain, and Ownership System (PECOS), and associated with a valid reassignment of billing rights to the Taxpayer Identification Number (TIN) entered in Item 25.
• CMP services may be furnished by auxiliary personnel under general supervision, provided those personnel are employees, leased employees, or contractors of the billing provider. When CMP services are furnished by auxiliary personnel, the supervising Medicare-enrolled practitioner’s NPI must be reported as both the rendering practitioner (Item 24.J.) and the supervising practitioner (Item 17) on the claim.

Billing Provider (Item 33.A. Billing Provider NPI)

• Enter the Type 2 (organizational) NPI of the billing provider or group. The NPI in this entry must be associated in PECOS with the TIN (entered in Item 25).

Other Details

• Billing for CMP services does not affect or replace existing Medicare billing for office visits or other distinct covered services.
• Documentation of the review of clinical updates electronically shared by the ACCESS Participant to the billing clinician is required to support each CMP claim.
• Recognizing the variation in the number of practitioners comprising a beneficiary’s care team, the ACCESS Model does not cap the number of clinicians who may bill the CMP for the same beneficiary. CMS will monitor billing patterns to identify potential duplication or abuse.
• CMP claims should be submitted as professional claims using the 837P (or CMS-1500 for paper claims), except for FQHCs and RHCs, which should submit institutional claims using the 837I (or CMS-1450/UB-04 for paper claims).

CMP Billing Guidelines for FQHCs and RHCs

Effective Date and Eligible Provider Types

Federally Qualified Health Center (FQHC) and Rural Health Clinic (RHC) billing for the ACCESS Co-Management Payment (CMP) Healthcare Common Procedure Coding System (HCPCS) codes are effective for dates of service on or after October 1, 2026.

All Medicare-enrolled FQHCs and RHCs are eligible to bill the CMP. Eligible clinicians must furnish the services described in the primary CMP guidance listed below.

Claims and Submission Requirements

FQHC and RHC CMP claims are submitted as institutional claims. FQHCs and RHCs should submit CMP claims electronically using the 837I transaction or, if eligible to submit paper claims, using Form CMS-1450 (UB-04). The same overall requirements apply as described in the CMP billing guidelines, unless noted otherwise in this guidance.

For more information, see CMS-1450 Form for cross-walking and Chapter 25 of Medicare Claims Processing Manual for general guidelines for Medicare Part A billing.

Beneficiary Identification (Form Locator [FL] 3a. Patient Control Number)

• Input the beneficiary's Patient Control Number. 

Type of Bill (FL4.)

Procedure Codes (FL 44. HPCS)

• From the Payment Amounts and HCPCS Codes table in the CMP billing guidelines, enter the G-code corresponding to the beneficiary’s ACCESS track. 
• When applicable, enter the AC modifier with the HCPCS code.

Date(s) of Service (FL 45. Service Date)

• The Service Date must correspond to the date on which the documented review or care-coordination activity occurred and while the beneficiary is aligned to your ACCESS track. CMP claims must be submitted within standard Medicare timely filing limits.

Service Units (FL 46. Units of Service)

• Enter the number of days or units of service provided to the aligned beneficiary for each service date. You must always use whole number units. For ACCESS CMP services, always enter “1” unit per claim line. 
• As a reminder, the CMP is payable up to 3 times every 12 months, per beneficiary, per ACCESS track. Exceeding these specifications will result in denied claims.

Total Charges (FL 47.)

• From the Payment Amounts and HCPCS Codes table in the CMP billing guidelines, enter the payment amount corresponding to the beneficiary’s ACCESS track.

Billing Provider (FL 56. Billing Provider National Provider Identifier [NPI])

• Enter the Type 2 (organizational) NPI of the billing provider or group. The NPI in this entry must be associated in PECOS with the Taxpayer Identification Number (TIN) (entered in FL 76-79).

Diagnosis Information (FL 67. Principal Diagnosis Code)

• Enter the aligned beneficiary’s ACCESS track-specific diagnosis using the highest level of specificity available. 
• At least one of the diagnosis codes on the billed claim must correspond to one of the qualifying conditions for the applicable ACCESS track, as specified under Section 3.0.2.4 Value Sets of the Artifacts Page of the ACCESS Model API Implementation Guide.
• Claims without valid principal diagnosis codes corresponding to the track of the billed CMP will be denied.

Have a question not answered here? Visit the ACCESS Model webpage or contact CMS at ACCESSModelTeam@cms.hhs.gov.