Care Management Strategies

WINTERGREEN / CLINICAL ADVISORY SERVICES

Care Management Strategy

Size the panel. Match the staffing. Build a program that pays for itself.

Since G0511 ended on January 1, 2026, Rural Health Clinics bill care management under the same individual codes as other practices, adding revenue outside the all-inclusive rate. We help RHCs decide when chronic, transitional, behavioral, and advanced primary care management make sense, and build programs that meet each code’s requirements while covering the staff who deliver them.

OUR FOCUS
01

Program Viability

Sizing the eligible panel and modeling break-even before adding staff.

02

Service Line Design

Choosing the right starting service among CCM, PCM, TCM, BHI, APCM, and RPM.

03

Documentation & Billing Controls

Consent, care plans, time tracking, and billing rules that hold up month after month.

THE CHALLENGE

Panel Size Determines Whether a Program Pays.

Margin = Patients billed × Net payment − Program cost

Most of a care management program’s cost is a care manager’s salary, so the program breaks even only once enough patients are enrolled and billed each month. Enrollment alone does not count; months without the required service elements cannot be billed.

Wintergreen helps clinics answer the core question first: is the enrolled, billed panel large enough to cover the staff who deliver the service, while meeting each code’s requirements? From there, we build the program in the right order.

WHAT WE HELP ANSWER

Does Care Management Make Sense for Your Clinic?

  • How many patients in your panel qualify, and how many can realistically be enrolled and billed each month?
  • Which service should you start with: chronic care, transitional care, or the advanced primary care bundle?
  • Should the program be staffed in-house or through an overseen vendor?
  • Are consent, care plans, and time tracking documented well enough to bill?
  • Are patients told up front that coinsurance and the deductible apply?
WHERE DO YOU STAND?

Billed Patients Decide Break-Even.

Monthly billed patients, not enrollment, determine whether a care manager’s salary is covered.

60 patients ≈ $3,300 / month

Below break-even. Grow enrollment before adding staff.

115 patients ≈ $6,300 / month

Roughly covers one care manager at $75K loaded cost.

200 patients ≈ $11,000 / month

Funds the program and supports a second service line.

Illustrative, assuming $55 of average payment per patient month before coinsurance collection. Rates vary by code and locality.

SERVICES & CORE REQUIREMENTS

What Each Service Requires Monthly

Service Patients Monthly Requirement
CCM Two or more chronic conditions Consent, care plan, and code-specific time, such as 20 minutes of clinical staff time.
PCM One complex, high-risk condition Disease-specific care plan and code-specific time.
TCM Recent discharge Contact within two business days; visit within 7 or 14 days.
BHI / CoCM Behavioral health condition Assessment, care planning, and code-specific time.
APCM Patients receiving primary care No time threshold; three levels by complexity.
THE DECISION FRAMEWORK

Six Gates, Taken in Order.

A sustainable care management program is built in sequence, from sizing the eligible population to reviewing results every month.

01

Eligible Population

A registry of patients with qualifying conditions, sized before staffing.

02

Consent & Cost Sharing

Documented consent, with patients told that coinsurance and the deductible apply.

03

Staffing Model

Clinical staff under general supervision, in-house or through an overseen vendor.

04

Documentation

Care plans, time tracking where codes require it, and 24/7 access to the care team.

05

Billing Rules

One practitioner per service per month, and no overlap between codes that cannot be billed together.

06

Monitoring

Enrollment, billing rate, collections, and readmissions, reviewed monthly.

BUILDING THE PROGRAM

Five Ways to Build Care Management.

Start with the service that fits your largest eligible group, then add service lines as each program covers its cost.

CCM

Start with Chronic Care

The largest eligible group in most rural panels.

TCM

Connect to Discharges

Strongest with a CAH or referring hospital that shares discharge notices.

APCM

Consider the Bundle

No time threshold; generally not billed with CCM or PCM in the same month.

BHI

Add Behavioral Health

Builds on an integrated provider or psychiatric consultant.

RPM

Add Remote Monitoring

Only when device logistics and data review are staffed.

WHEN TO WAIT

Signs a Program Isn’t Ready

  1. The eligible panel cannot reach break-even.
  2. No one is assigned to enroll patients and track time.
  3. Patients have not been told about cost sharing.
  4. A vendor would run the program without clinic oversight.
THE WINTERGREEN APPROACH

Size First. Then Launch Care Management.

Before launching, we size the eligible panel and match staffing to the number of patients you can enroll and bill each month, so the program is built to cover its cost from the start.

STEP 01

Size

Build a registry of eligible patients and model how many can be enrolled and billed each month.

STEP 02

Staff

Match care manager capacity to the billable panel, in-house or through an overseen vendor.

STEP 03

Launch

Start with one service and put consent, documentation, and billing controls in place.

STEP 04

Expand

Review results monthly and add services only once the first program covers its cost.

THE VALUE WE DELIVER

Sustainable Programs. Better-Supported Patients.

When care management is sized to the panel, staffed to the billable volume, and documented to each code’s requirements, clinics add revenue outside the all-inclusive rate while giving patients with chronic, behavioral, and post-discharge needs consistent support between visits.

New Revenue Outside the AIR

Individually billed care management services that fund the staff who deliver them.

Compliant, Billable Months

Consent, care plans, time tracking, and billing rules in place so every eligible month can be billed.

Stronger Patient Continuity

Ongoing care team contact, smoother post-discharge follow-up, and readmissions tracked monthly.

Sources: CMS CY 2025 and CY 2026 Physician Fee Schedule final rules (RHC/FQHC care management billing); CMS MLN Care Management Services. Figures current as of November 2026. Examples illustrative.

CONNECT WITH WINTERGREEN

Does Care Management Make Sense at Your Clinic?

A program that is too small to cover its staff, or that misses required elements, can cost more than it brings in.

Connect with Wintergreen to talk through a care management program at your clinic, from sizing the eligible panel to choosing the right first service and building the controls that keep it billable.

Nicole Thorell, Wintergreen Principal
YOUR POINT OF CONTACT

Nicole Thorell

RN, MSN, FNP‑C
Principal | Wintergreen

View Professional Profile →
190 U.S. Route 1, Ste 215, Falmouth, ME 04105 info@wintergreenme.com 207.280.6495