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 patients enrolled in an ACCESS track. Beneficiary 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 2026
• Rural Health Clinics (RHCs) – beginning October 2026
• Pharmacists – guidance forthcoming
• Medical Supply Companies with Pharmacists - guidance forthcoming

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;
• 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

Date and Place of Service

• Date of Service (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): Must reflect the practice setting of the rendering practitioner, as appropriate.

Diagnosis Code

• The diagnosis code on the billed CMP HCPCS code must correspond to one of the qualifying conditions for the beneficiary's ACCESS track
• The billed HCPCS code must also correspond to a track to which the beneficiary is aligned
• Claims will be denied if a corresponding diagnosis code is not included

Practitioner NPI / TIN

• The rendering practitioner’s NPI must be reported on the claim.
• 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 and the supervising practitioner on the claim.
• The rendering practitioner's practice TIN and NPI must be reported as the billing practitioner, consistent with standard Medicare Part B billing requirements
• The referring practitioner may optionally be reported on the claim.

Documentation

• Documentation of the review of clinical updates electronically shared by the ACCESS Participant to the billing clinician is required to support each CMP claim.

Other Details

• Billing for CMP services does not affect or replace existing Medicare billing for office visits or other distinct covered services.
• 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.
• Billing guidelines specific to FQHCs, RHCs, Pharmacists, and Medical Supply Companies with Pharmacists are forthcoming.

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