A practical billing workflow for Medicare ACCESS Co-Management Payments, including practitioner review, care-coordination action, time, diagnosis, documentation, and frequency controls.
CMS expanded the ACCESS Model on September 15, 2026 and published detailed billing guidance for the model’s Co-Management Payment. Eligible Medicare Part B practitioners can bill when they review an ACCESS care update and perform related care coordination. Model participation is not required to bill the payment, but receiving the update by itself does not meet the billing requirements.
The practitioner must review and act
CMS requires the eligible practitioner to review an ACCESS care update for the beneficiary and track, then perform at least one care-coordination activity. Examples include reconciling medication, updating the problem list, modifying follow-up instructions, coordinating with other clinicians, communicating with the ACCESS organization, or documenting agreement or disagreement with a recommendation and the rationale.
A minimum of five minutes of total practitioner time is required for the review and associated activity. Operationally, the practice needs a way to route the update to an eligible practitioner, capture the date and time, and preserve the action taken in the clinical record.
The claim needs the right track and diagnosis
CMS uses three HCPCS codes: G0676 for early or established cardio-kidney-metabolic tracks, G0677 for the musculoskeletal track, and G0678 for the behavioral-health track. Each has a stated allowed amount of $30 before applicable geographic adjustment and sequestration.
At least one diagnosis on the claim must correspond to a qualifying condition for the applicable ACCESS track. CMS says the claim will be denied when the corresponding diagnosis is missing. The date of service is the date the documented review or coordination activity occurred, and the place of service should reflect the rendering practitioner’s practice setting.
Frequency is a revenue-cycle control
The Co-Management Payment is payable up to three times every 12 months, per beneficiary, per ACCESS track. A practitioner may bill across multiple tracks when the work is distinct for each track. The AC modifier may be added for qualifying onboarding support, but only once per billing provider, beneficiary, and track.
This makes a track-level register useful. Record the beneficiary, ACCESS organization, track, care-update date, practitioner, documented action, time, diagnosis, HCPCS code, prior payments, and whether the AC modifier has already been used.
Receipt creates the task—not the claim
The billing team should not convert every incoming ACCESS update into a charge. First route it to the practitioner, then verify the documented review, care-coordination action, minimum time, qualifying diagnosis, correct track code, and remaining frequency allowance.
Beneficiary cost-sharing does not apply to the Co-Management Payment. The practical rule is simple: receipt creates a task; supported practitioner action creates the billing opportunity.
Practical takeaway
Route each ACCESS care update to an eligible Medicare Part B practitioner.
Document the review, at least one care-coordination activity, and five or more minutes of practitioner time.
Match the HCPCS code and qualifying diagnosis to the beneficiary’s ACCESS track.
Track the three-per-12-month frequency limit separately for each beneficiary and track.
Do not assign beneficiary cost-sharing to the Co-Management Payment.