What APCM consent needs to cover

CMS requires a practice to obtain written or verbal patient consent before APCM services begin and document it in the medical record. The patient should be told that only one provider can furnish and be paid for APCM services during a calendar month, that the patient may stop services at any time, and that cost sharing may apply.

  • Identify the practice and the APCM service in language the patient can understand
  • Explain that only one provider may furnish and be paid for APCM in a calendar month
  • Explain the patient’s right to stop services at any time
  • Explain that Medicare cost sharing may apply
  • Record whether consent was written or verbal, plus the date and responsible staff
  • Give the patient a clear contact path for questions or withdrawal

Sample APCM consent language to review

Starting point only.

This example is educational and intentionally general. Have qualified legal, compliance, billing, and clinical leaders adapt it to your practice, patient population, state law, payer requirements, and operating model before use.

Build consent into the enrollment workflow

  1. Confirm the patient and program fit. Verify identity, attribution, initiating-visit status, and the practice’s ability to furnish APCM services.
  2. Explain before asking. Describe what the service includes, who remains responsible for care, possible cost sharing, and how the patient can get help.
  3. Capture consent consistently. Record the method, date, patient or representative, staff member, source document, and any questions or accommodations.
  4. Make withdrawal operational. Give staff a defined way to receive, document, route, and act on a patient’s request to stop services.

APCM consent questions

Can consent be verbal?

Yes. CMS permits written or verbal consent, but it must be obtained before services begin and documented in the patient’s medical record.

Is consent required every month?

CMS states that consent only needs to be obtained once. The practice still needs a reliable process for questions, changes, and withdrawal.

Should the form promise a payment amount?

No. Cost sharing and coverage can vary. Use accurate, reviewed language and direct patients to the appropriate coverage and billing resources.

What happens if the patient stops?

Document the request, effective timing, and operational follow-through. Confirm how it affects that month’s services and billing with qualified reviewers.

Primary sources and examples