Medicare’s new APCM bundle gains traction, but reach stayed narrow in year one
Medicare’s Advanced Primary Care Management bundle got off the ground in 2025 with real momentum, but the first full look at claims data shows a model still searching for scale. Use expanded quickly across the year, driven largely by primary care practices that saw a chance to be paid for work that has long gone uncompensated: medication follow-up, care coordination, patient outreach and other tasks done between visits.
The numbers are real, and so are the barriers. APCM spending reached $130.7 million in 2025, yet the program still covered only 344,000 beneficiaries in the fourth quarter, about 1.2% of Medicare fee-for-service enrollees. For a payment model designed to support longitudinal primary care, that is a meaningful start and a small footprint at the same time.
Claims growth came fast, especially from early nonusers
The APCM model began on Jan. 1, 2025, as a monthly bundled alternative to billing separately for chronic care management, principal care management and transitional care management. Practices can bill one of three codes depending on patient complexity: G0556 for patients with one or fewer chronic conditions, G0557 for patients with two or more chronic conditions, and G0558 for patients with two or more chronic conditions who are Qualified Medicare Beneficiaries.
The first-year claims analysis found 2.49 million beneficiary-months and 9,748 clinicians billing the codes at some point, across 1,951 billing entities. Primary care specialties accounted for 93.6% of claims, led by family medicine, nurse practitioners and internal medicine. The Level 2 code, G0557, dominated use, accounting for about 80% of claims and 68% of allowed dollars.
Use grew 2.7-fold from the first quarter to the fourth quarter of 2025. Nearly two-thirds of that increase came from clinicians who were not billing APCM in the first quarter. In practical terms, adoption did not depend solely on a small core of early believers; it widened as the year progressed.
The turnover was harder to interpret. Between 12% and 16% of billing clinicians dropped out from one quarter to the next, and the early claims window did not explain why. Some practices may have been experimenting, some may have run into administrative friction, and some may simply have decided the model did not fit their patient mix or workflow.
A monthly copay is pushing patients and practices away
APCM’s biggest obstacle may be the simplest one: cost-sharing. Because the service is billed under Part B, patients without supplemental coverage owe a monthly coinsurance payment, about $3 for Level 1 and $10 for Level 2. Roughly 13% of beneficiaries in Original Medicare lack supplemental coverage, and that group faces the charge every month the service is billed.
In a summer 2026 survey of 176 respondents familiar with APCM, 42% said collecting monthly copays was the biggest implementation barrier. More than half selected waiver of copays for beneficiaries without supplemental coverage, while holding clinicians harmless, as the single policy change most likely to increase adoption.
Patient reactions can be abrupt. At one safety net health system, patients accepted team-based services until staff explained the copay and the possibility of an unknown deductible, at which point enrollment collapsed and the organization paused its rollout.
“Massive problem” is how one family physician described the beneficiary cost-sharing. Patients often understood the value of extra support once it was explained, but the money exchange changed the conversation. It made clinicians feel as though they were selling access to care rather than offering a service meant to keep patients healthier between visits.
Early adopters see operational value, not instant financial rescue
Independent practices appear to see APCM less as a standalone revenue engine and more as one part of a broader business model. A rural Arkansas family physician described how fee-for-service pressures still reward speed over continuity, even when patients want more time and more follow-up. For that practice, APCM payments are paired with remote patient monitoring and shared savings from a Medicare accountable care organization.
In that setting, APCM helps underwrite the work that keeps patients from drifting through the cracks. It does not replace the rest of the revenue structure, and no one pretends otherwise.
One clinically integrated network serving independent practices has also been providing support that many small offices cannot easily afford on their own: technology tools, consent scripts and operational guidance. A former Medicare program operations director for the network said the economics are straightforward—preventing a single major inpatient event may cover a year’s worth of APCM services for multiple patients.
That logic fits the kind of care APCM is meant to support. The payment is not about a single encounter. It is about maintenance, surveillance and the work that happens when a patient is not in the room.
Awareness, consent and billing complexity still limit uptake
The companion survey in Journal of General Internal Medicine helps explain why adoption did not spread more rapidly. Barriers to use were cited by 41.6% of respondents, and 14.9% said they were using APCM codes. A much larger share, 43.6%, were nonusers who had never heard of APCM codes at all.
In other words, the problem was not only economics. It was also basic visibility. A payment model cannot transform care if the clinicians who would use it do not know it exists or cannot fit its consent and documentation requirements into daily practice.
APCM does differ from the older care management codes in one important way: it does not require time tracking. Practices must still secure patient consent, provide 24/7 access and maintain a care plan, among other requirements. Those obligations are meant to support better continuity, but they also create administrative work at a moment when many primary care groups are already stretched thin.
Policy fixes are now aimed at scale, not just adoption
The Primary Care Collaborative urged CMS and Congress to make the model easier to use by removing beneficiary cost-sharing, simplifying consent and re-consent, and building stronger alignment across payers. The report also argued that APCM should be treated as an on-ramp to accountable care and hybrid payment, where prospective population-based payment is layered with fee-for-service.
Waiving copays is not a trivial administrative tweak; it would require congressional action. The report pointed to the proposed 2027 Medicare Physician Fee Schedule, which would allow accountable care organizations and participating clinicians to waive beneficiary coinsurance for certain Part B services. That policy direction matters because APCM cannot scale widely if each monthly charge becomes a barrier at the point of enrollment.
For now, the first-year evidence points to a model with clear clinical logic, decent early uptake among primary care clinicians and a reach that is still too modest to reshape Medicare spending on its own. The harder questions are still practical ones: whether practices can absorb the workflow, whether patients will accept monthly cost-sharing, and whether policymakers will decide that the support primary care provides between visits should be treated as a core benefit rather than an optional add-on.