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Billing CCM Care Plan Code (G0506) and ACP (99497/99498)

Hello!
We are currently having discussions around the appropriateness of billing the CCM Care Plan Code (G0506) with ACP codes (99497/99498). There is no NCCI edit that prevents these codes from being billed together, but it seems like a muddy area.

Our concerns are that the conversations and work that goes into billing the G0506 code often overlaps with the conversation and work that goes into billing ACP codes. But at the same time, during a CCM initiating visit, if a provider performs extensive assessment and CCM care planning, documents the status assessment and plan for each chronic condition, and also documents a conversation around ACP that reaches at least 16 minutes, would it be appropriate to bill for both the G0506 and 99497 codes?

Any insight/opinions on this topic would be much appreciated!

Medical Billing and Coding Forum