Practice Operations  ·  8 min read

Advance Care Planning Billing 2026: CPT 99497, 99498, Same-Day Rules & Documentation

Advance Care Planning (ACP) is one of the most consistently under-billed preventive services in primary care and geriatrics. Every eligible patient conversation about end-of-life wishes, healthcare proxies, and treatment directives represents a billable encounter — and most practices capture fewer than 20% of those encounters on a claim.

What Is Advance Care Planning?

Advance Care Planning is a voluntary, face-to-face service in which a physician or other qualified healthcare professional discusses an individual's health care wishes regarding a potential future incapacity to make decisions. This includes explaining and discussing advance directives such as standard forms, living wills, and durable powers of attorney for healthcare.

ACP conversations are not the same as a general discussion of prognosis. They must specifically address what the patient wants to happen if they become unable to make their own healthcare decisions, and optionally involve completion or updating of advance directive documents.

ACP CPT Codes 2026

CodeDescription2026 Medicare Rate (National)
99497ACP including the explanation and discussion of advance directives — first 30 minutes, face-to-face~$86
99498Each additional 30 minutes (add-on to 99497)~$75

Key rule: 99497 is a standalone code for the first 30 minutes. 99498 is an add-on code for each additional 30-minute block. A 65-minute conversation = 99497 + one unit of 99498. A 95-minute conversation = 99497 + two units of 99498.

Who Can Bill ACP?

ACP can be billed by:

The conversation doesn't have to be with the patient alone — a family member or surrogate decision-maker can be present and the service can still be billed, provided the patient or their legal representative has consented.

Medicare Coverage: Voluntary, Not Annual

Under Medicare, ACP is covered as a voluntary preventive service. This means:

Same-Day Billing Rules

This is where most billing confusion occurs. ACP can be billed on the same day as:

Annual Wellness Visit (G0438 or G0439)

ACP billed same-day as an AWV has patient cost-sharing waived for Medicare. This is the most common and highest-value combination. The ACP discussion must be distinct from the AWV components and documented separately.

E/M Visit (99202–99215)

ACP can be billed on the same day as a medically necessary E/M visit with modifier 25 on the E/M code (or, depending on payer, no modifier — verify by payer contract). The two services must be separately documented. Commercial payers vary significantly — some require that ACP be on a different date from E/M visits.

Transitional Care Management (99495, 99496)

ACP can also be billed alongside TCM codes when the ACP conversation occurs during the TCM period and is separately documented.

Important: When ACP is billed on the same day as an E/M visit that's NOT the AWV, Medicare patient cost-sharing (deductible and coinsurance) applies to the ACP service. Only the AWV combination triggers the cost-sharing waiver.

Documentation Requirements

Documentation must include all of the following to support ACP billing:

Time is the key driver: 99497 requires the ACP discussion to be at least 16 minutes to bill the first 30-minute block (per CMS time-rounding rules). 99498 requires at least 16 additional minutes beyond the first 30. Document total ACP time clearly and separately from E/M or AWV time.

Telehealth ACP Billing

ACP is included on the Medicare telehealth services list, meaning it can be billed via synchronous audio-video telehealth using the same 99497/99498 codes with Place of Service 02 (telehealth, patient not at home) or POS 10 (telehealth, patient at home). Audio-only (telephone) ACP is also covered through 2026 with modifier 93.

Common ACP Billing Denials and Prevention

1
Time not documented separately from visit time
ACP time must be its own documented block — not bundled into total visit time. Prevention: create a separate ACP note section in your EHR template that captures ACP-specific start/end time.
2
Missing voluntary consent notation
Medicare requires documentation that the patient voluntarily agreed to the ACP discussion. Prevention: add a standard sentence to your ACP template: "Patient agreed to participate in ACP discussion voluntarily."
3
Bundled with AWV without separate documentation
ACP billed same-day as AWV must be separately documented — not folded into the AWV note. Prevention: use a distinct ACP note or sub-section separate from G0438/G0439 documentation.
4
99498 billed without 99497 as primary
99498 is an add-on code — it can't be billed alone. Prevention: billing software should require 99497 as a parent code before allowing 99498.
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