TCM Billing: The 2-Business-Day Rule (99495, 99496)

Transitional care management (TCM) billing has three hard requirements. Clinical staff must make interactive contact with the patient or caregiver within 2 business days of discharge. A face-to-face visit must follow within 14 days (99495) or 7 days (99496). And you bill once for the 30-day period. Two documented failed contact attempts still count.

What TCM pays for

TCM covers the 30 days after a patient leaves a facility. The period starts on the discharge day and runs for the next 29 days. It pays for the work of keeping that patient out of the hospital: the first contact, the follow-up visit, medication reconciliation, and coordination. See our TCM glossary entry for a short definition.

Only 1 physician or non-physician practitioner (NPP, such as a nurse practitioner or physician assistant) can report TCM per patient per period. You report it once.

Qualifying discharges include:

• Inpatient acute care hospital
• Inpatient psychiatric hospital
• Inpatient rehabilitation facility
• Long-term care hospital
• Skilled nursing facility (SNF)
• Hospital outpatient observation
• Partial hospitalization, including at a community mental health center

The requirements, code by code

The dollar figures are 2026 national non-facility amounts. Your locality will differ, so check the CMS PFS Look-Up Tool.

Medical decision making (MDM) is how complex the clinical thinking was at the visit. It weighs the problems addressed, the data reviewed, and the risk of the treatment choices. Don't pick 99496 just because you saw the patient within 7 days. The MDM has to support it.

Medication reconciliation must happen on or before the face-to-face visit date.

The 2-business-day contact, in detail

CMS's TCM booklet sets the rules for the first contact:

• Who: "clinical staff who can address patient status and needs beyond scheduling follow-up care." A scheduler confirming a time doesn't meet it.
• How: by phone, by email, or face-to-face.
• When: within 2 business days after discharge.
• With whom: the patient or their caregiver.

If you can't reach the patient, you can still bill. CMS says "you may report the service if you make 2 or more unsuccessful separate contact attempts in a timely manner." You still need the timely face-to-face visit. Document every attempt with a date and time.

How TCM interacts with CCM and APCM

CCM: CMS allows CCM codes during the 30-day TCM period when medically reasonable and necessary, as long as the same time isn't counted twice. A patient can be in both.

APCM: the same practitioner can't bill APCM and TCM for the same patient in the same month. Another clinician in the group can still bill TCM. If a patient qualifies for both in a month, AAFP says the practice may choose which one to report. Our CCM vs APCM guide covers that choice.

ADT notifications are your trigger

You can't call a patient you don't know was discharged. That's where ADT notifications come in. ADT stands for admission, discharge and transfer. Read more in our ADT notification glossary entry.

Under the Medicare hospital conditions of participation, hospitals with conforming electronic systems must send event notifications. These go out when a patient is admitted or registered in the ED, and at discharge or transfer. Recipients include the patient's established primary care practitioner or practice group.

In practice, these notices land in an inbox, a fax queue, a health information exchange portal, or a daily file. The 2-business-day clock is already running when they arrive.

Why the 2-day contact is an outreach problem

TCM rarely fails on clinical skill. It fails on logistics:

• The notice sits unread on a Friday afternoon.
• The first call goes to voicemail and nobody tries again.
• The patient answers, but the person calling can't book the visit.
• Nobody writes down the attempts, so the failed-contact rule can't be used.

Here's a staffing model that works.

Where AI calls fit

AI calling handles the reach. Clinical staff handle the contact that counts. The split looks like this:

1. You upload or connect the discharge list. Rivvi reads it, enriches it against CMS and NPI registry data, and builds the call queue.
2. On the Team plan, Rivvi calls each patient promptly and checks whether they're available to talk.
3. When the patient answers, Rivvi warm-transfers them live to your nurse or care coordinator. It can navigate your phone tree to reach the right department. Your clinical staff do the status check and book the visit in your EHR.
4. If no one can take the transfer, Rivvi creates a follow-up task with the patient's details.
5. Every attempt and outcome is logged in Rivvi and pushed to HubSpot, Salesforce or Zoho if one is connected. That gives you the attempt record the failed-contact rule depends on.

Rivvi doesn't book into your EHR schedule or write to the chart. It gets the patient on the phone with the person who can. TCPA opt-out is honored on every call and text.

At scale, Southeast Medical Group reached 104,000+ patients with Rivvi, with a 0.45% opt-out rate (August 2026). Live answer rates on Rivvi outbound calls run about 40%. That's why the second attempt matters. See how this works for care transitions.

Sources

• CMS MLN908628: Transitional Care Management Services (August 2025)
• CMS MLN909188: Chronic Care Management Services (June 2025)
• AAFP: Advanced Primary Care Management
• eCFR: 42 CFR 482.24, Condition of participation: Medical record services
• MedFeeSchedule: CPT 99495, 2026 national amount
• MedFeeSchedule: CPT 99496, 2026 national amount
• CMS Physician Fee Schedule Look-Up Tool