CCM and APCM Enrollment Texts: Invite Patients, Then Get Consent Right

Chronic care management outreach by text, from first invite to follow-up. What Medicare requires before you bill, and why the invite is not the consent.

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The short answer

Chronic Care Management (CCM) is for patients with two or more chronic conditions expected to last at least 12 months, or until death, that put them at significant risk. Advanced Primary Care Management (APCM, HCPCS G0556 to G0558) is a monthly bundle billed by the practitioner who takes responsibility for the patient's primary care. Both need the patient's consent, verbal or written, documented in the medical record before you bill. The patient must be told the service is available, that cost sharing may apply, that only one practitioner can bill it each month, and that they can stop at any time. A text invite starts that conversation. It is not the consent. Use broadcasts to reach eligible patients, then have staff explain the required items and record the answer.

Risky vs safe: CCM invites, rewritten

A regular text can't contain PHI, and naming a care-management program for chronic conditions points to a diagnosis. Keep regular texts generic and put program details in a Secure text with link.

  • Risky

    Hi Ann, you qualify for our Chronic Care Management program because of your diabetes and COPD.

    Safer

    Hi {{first_name | there}}, Riverside Family Clinic has a program with extra support from your care team between visits. Call (555) 010-0142 to hear more. Reply STOP to opt out.

    Diagnoses don't belong in a regular text, which can't contain PHI.

  • Risky

    Reply YES to enroll in Chronic Care Management.

    Safer

    Reply with a good time, and a nurse will call to explain the program and ask if you'd like to join.

    A one-word reply skips the items CMS says you must explain and document before you bill.

  • Risky

    It's free with Medicare.

    Safer

    Medicare covers this service, and your usual cost sharing may apply.

    CMS requires you to tell patients about possible cost sharing. "Free" is wrong for most of them.

Who is eligible for CCM and APCM

CMS describes CCM patients as having multiple (two or more) chronic conditions expected to last at least 12 months or until death, that place them at significant risk of death, acute exacerbation or decompensation, or functional decline (CMS CCM booklet). CMS requires an initiating visit before CCM starts for new patients and for patients you haven't seen in the previous year. That visit can be a comprehensive E/M visit, an annual wellness visit or an initial preventive physical exam, and CCM has to be discussed during it.

APCM started on 1 January 2025 with three levels: G0556 for patients with 0 or 1 chronic condition, G0557 for 2 or more, and G0558 for Qualified Medicare Beneficiaries with 2 or more (CY 2025 Physician Fee Schedule final rule). It is billed monthly by the practitioner who intends to be responsible for the patient's primary care. An initiating visit is required only for new patients, meaning patients not seen by your practice in the previous 3 years.

What CMS says consent requires

For CCM, CMS says to get written or verbal consent before you bill. You inform the patient, and document in the medical record: that CCM is available, their possible cost sharing, that only one practitioner can provide and bill CCM in a calendar month, their right to stop at any time (effective at the end of the month), and that you explained this and whether they accepted or declined. Consent is needed once, unless the patient switches practitioners.

APCM consent follows the same pattern, with more to explain. The patient hears that APCM is available, that Medicare cost sharing usually applies, and that you intend to be responsible for all their primary care. They hear that only one practitioner can be paid for APCM each month, that this doesn't limit care from other practitioners, that APCM is ongoing and monthly, and that they can stop at any time. CMS says written consent is not necessary. A patient moving from CCM to APCM needs a new consent.

Why the invite is not the consent

CMS describes consent as the patient being informed of each required item, with the explanation and the answer documented in the medical record. CMS does not describe a text message as a way to get consent. A short invite does not carry every required item, and a "YES" reply does not show the patient heard them.

The safe pattern is to invite by text and then explain by phone or at a visit. Staff walk through the items and record the answer in the medical record. If your practice wants to collect written consent through a Secure text, make sure the message carries every required item and the patient's reply is documented in the medical record. Check that process with your compliance lead before you rely on it.

What practices try first

Most practices raise CCM at visits and through phone campaigns. Visits only reach patients who come in. Phone lists stall because patients don't answer unknown numbers. A text first means the call that follows is expected, and patients can reply with a time that suits them.

Consent rules for the texts themselves

Under HIPAA, a communication describing a health-related service provided by your own practice is generally not "marketing," unless a third party pays you to send it (45 CFR 164.501). FCC rules separately require prior express written consent for autodialed texts that advertise or telemarket. They make an exception for a HIPAA "health care" message from a covered entity, which needs prior express consent instead (47 CFR 64.1200(a)(2)). Text only patients who have agreed to texts from your practice. Honor opt-outs within 10 business days, and send between 9am and 8pm in the patient's time zone.

How to send it in BloomText

Export a list of eligible patients from your EHR as a CSV, with MRN, phone, first name and columns such as provider_last_name. In BloomText, open Broadcast in the sidebar and work through Details, Recipients and Message. Choose Secure text with link (can contain PHI) for invites that name the program, or Insecure text (can't contain PHI) for a generic first touch. See create a broadcast and add recipients.

Upload up to 20,000 rows and map the columns. BloomText matches rows by MRN, then phone, then email, and doesn't change existing records. Write the message with variables and fallbacks, such as {{first_name | there}} (personalize messages). Schedule it for a weekday morning in the patient's time zone and set the time between messages so replies arrive at a pace your care managers can handle. You can pause and resume (send and track).

Replies come back as private one-to-one conversations in your team inbox, where a care manager can pick up each one and book the consent call. Numbers on your org's opt-out list aren't texted. In an Insecure broadcast they show as Failed with the reason. BloomText does not record consent in your EHR. Staff document it in the medical record as CMS requires.

Broadcasts need the Patient SMS Add-on, membership in a team with an assigned phone number, and a verified account. BloomText verifies new accounts before their first broadcast. Broadcast runs in the BloomText web and desktop apps. The BAA is included on every plan, including the free plan.

What may change

In the CY 2027 Physician Fee Schedule proposed rule, CMS asked for comment on how the care-management code family should work, including what should trigger it. That is a request for comment, not a rule change. The consent rules above are the ones in force on 15 October 2026. If your practice also runs remote monitoring, see RPM patient engagement texts. CMS lets you bill RPM or RTM, but not both, alongside CCM.

Sample CCM and APCM enrollment texts

These are informational invitations from your own care team, not promotions, and none of them is the consent. Send them only to patients who have agreed to texts from your practice. Variables such as {{provider_last_name}} come from your CSV.

  • Generic first touch

    Insecure text: can't contain PHI

    Hi {{first_name | there}}, Riverside Family Clinic now offers monthly support from your care team between visits. We'll explain it on your next call or visit, or call (555) 010-0142 to ask. Reply STOP to opt out.

    No program name or condition, so it works as a regular text.

  • CCM invite

    Secure text with link: can contain PHI

    Hi {{first_name | there}}, Dr. {{provider_last_name | your provider}} thinks you may benefit from Chronic Care Management at Riverside Family Clinic. It is monthly support from your care team between visits, with a care plan, help with medications and referrals, and a way to reach us any time. Medicare covers it, and your usual cost sharing may apply. A nurse will call to explain the details and ask if you'd like to join. You can say no, and you can stop at any time. Questions? Reply here or call (555) 010-0142.
  • APCM invite

    Secure text with link: can contain PHI

    Hi {{first_name | there}}, Riverside Family Clinic offers Advanced Primary Care Management to patients who get their primary care here. Your care team would be your main point of contact, with monthly support between visits. Medicare cost sharing usually applies, and some supplemental plans cover it. Only one practice can provide this service each month, and it doesn't stop you from seeing other providers. We'll call to go over it and ask if you'd like to join. Questions? Call (555) 010-0142.
  • Follow-up after no answer

    Secure text with link: can contain PHI

    Hi {{first_name | there}}, we tried to reach you about the care program Dr. {{provider_last_name | your provider}} mentioned. Reply with a good time for a 5-minute call, or call us at (555) 010-0142.
  • Visit needed first

    Insecure text: can't contain PHI

    Hi {{first_name | there}}, it's time to book a visit with Riverside Family Clinic. Call (555) 010-0142 to schedule. Reply STOP to opt out.

    For new patients, or CCM patients not seen in the past year, the initiating visit comes before the service starts.

  • Summary after verbal consent

    Secure text with link: can contain PHI

    Hi {{first_name | there}}, thanks for talking with us today about Chronic Care Management at Riverside Family Clinic. As we discussed: your care team will check in each month, your usual Medicare cost sharing may apply, only one practice can bill for this service each month, and you can stop at any time, effective at the end of that month. Questions? Reply here or call (555) 010-0142.

    A record for the patient. The consent is what staff documented in the medical record during the call.

Send CCM and APCM invites with the Patient SMS Add-on

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Frequently Asked Questions

Can a patient consent to CCM by text?
CMS asks for written or verbal consent, with the required items explained and the result documented in the medical record. It does not describe text messages as a consent method. A short invite or a "YES" reply does not show the patient was told each item. The safe route is to invite by text and get consent by phone or at a visit. If you want written consent through a Secure text, include every required item, document the reply in the medical record, and check the process with your compliance lead.
What must the patient be told before CCM?
That CCM is available, that cost sharing may apply, that only one practitioner can provide and bill CCM in a calendar month, and that they can stop at any time, effective at the end of the month. You document that you explained this and whether they accepted or declined.
Does a patient who consented to CCM need a new consent for APCM?
Yes. In the CY 2025 Physician Fee Schedule final rule, CMS said previous CCM consent is not enough for APCM. A patient moving from CCM to APCM needs a new consent.
Who needs an initiating visit?
For CCM, new patients and patients you haven't seen in the previous year. For APCM, only new patients, meaning patients not seen by your practice in the previous 3 years. CMS also counts certain patients who had care management from your practice in the past year as established for APCM.
Can the invite name the program or the patient's conditions?
Only in a Secure text with link, which can contain PHI. An Insecure text can't contain PHI. A program for chronic conditions points to a diagnosis, so keep regular texts generic, such as "monthly support from your care team between visits."
Is a CCM invite marketing?
Under HIPAA, describing a health-related service your own practice provides is generally not marketing, unless a third party pays you to send it. Under FCC rules, a HIPAA health care message from a covered entity needs the patient's prior express consent rather than written consent. Text only patients who have agreed to texts from you.

Sources

Last verified October 15, 2026.

  1. CMS MLN909188: Chronic Care Management Services (June 2025)
  2. Federal Register: CY 2025 Physician Fee Schedule final rule (Dec 9, 2024), APCM section
  3. Federal Register: CY 2027 Physician Fee Schedule proposed rule (Jul 16, 2026)
  4. eCFR: 45 CFR 164.501, HIPAA definition of marketing
  5. eCFR: 47 CFR 64.1200 (FCC robocall and robotext rules)