Advance care planning (ACP) billing under Medicare gets a structural change starting January 1, 2027.
CMS created two new HCPCS codes — G0572 for the first 20 minutes and G0573 for each additional 20 minutes — that separately capture qualifying clinical-staff time spent providing ACP under the billing practitioner’s direct supervision.
CPT codes 99497 and 99498 now report only the billing practitioner’s personally spent time. Both code families can be reported together when each family’s time threshold is met independently.
The CY 2027 PFS final rule (CMS-1848-F), published November 9, 2026, finalizes this separation. Here is what the rest of this article breaks down:
- The code-number conflict that billing teams should verify
- How the new G-codes differ from the existing CPT codes
- When practitioner & staff time can be combined
- Supervision and documentation requirements
- Telehealth eligibility for the new codes
TLDR — ACP BILLING 2027
Staff time gets its own codes. Practitioner time stays with 99497/99498.
- 🆕 G0572 — first 20 min of clinical-staff ACP time under direct supervision
- 🆕 G0573 — each additional 20 min of clinical-staff ACP time (add-on code)
- 🔒 99497/99498 now limited to the billing practitioner’s personal time only
- 🤝 Both code families reportable when each threshold is met — no double-counting minutes
- 📡 G0572 and G0573 added to the Medicare Telehealth Services List for 2027
How do the new ACP codes work?
CMS finalized G0572 and G0573 (originally proposed as GACP1 and GACP2) to describe clinical-staff time spent providing advance care planning.
The service includes explanation and discussion of advance directives and standard forms with the patient, family members, or surrogate — directed by the treating physician or other qualified health care professional.
G0572 and G0573 descriptors
G0572 covers the first 20 minutes of clinical-staff time. G0573 is the add-on code for each additional 20 minutes. CMS added “of clinical staff time” to G0573’s descriptor in the final rule for clarity.
The structure mirrors 99497/99498 in format but targets a different workforce. Where 99497 captures the practitioner’s first 30 minutes and 99498 captures each additional 30 minutes of practitioner time, G0572/G0573 capture clinical-staff time under supervision.
Time attribution rules
The 2027 separation creates a clean (if slightly complicated) framework for which time goes where:
| Code family | Whose time | Threshold | Use case |
| 99497 | Billing practitioner’s personal time | First 30 minutes | Practitioner delivers ACP directly |
| 99498 | Billing practitioner’s personal time | Each additional 30 minutes | Extended practitioner-delivered ACP |
| G0572 | Clinical-staff time | First 20 minutes | Staff delivers ACP under direct supervision |
| G0573 | Clinical-staff time | Each additional 20 minutes | Extended staff-delivered ACP |
Both families can be reported on the same encounter when each threshold is met independently.
A practitioner who spends 30 minutes and whose clinical staff spends 20 minutes during the same ACP session can report 99497 and G0572.
The one rule that cannot be broken: do not count the same minutes toward more than one code’s time requirement. The medical record must support the time used for each timed service.
Can practitioner and staff time be combined?
Yes — but only in one direction, and with a specific constraint. CMS allows practitioner time to be combined with clinical-staff time to meet the G0572/G0573 threshold when staff time alone falls short.
Consider a scenario where clinical staff provides 12 minutes of ACP and the practitioner adds 10 minutes. The staff’s 12 minutes alone do not meet the 20-minute G0572 threshold.
But CMS permits combining the practitioner’s 10 minutes with the staff’s 12 minutes (22 total) to reach the G0572 threshold — provided those practitioner minutes are not also counted toward 99497.
The reverse is not explicitly authorized. CMS did not describe adding staff time to meet the 99497/99498 practitioner-time thresholds under the 2027 framework. The prior policy allowed staff time to count under certain team-based conditions; that policy is superseded for 2027.
In practice, the risk is not in understanding the rule — it is in documentation. A billing team that submits both code families without time logs specific enough to show who spent how many minutes will have trouble surviving an audit. The documentation needs to track:
- Start and stop times (or total duration) for the practitioner
- Start and stop times (or total duration) for clinical staff
- Which minutes were combined, if applicable
- Confirmation that no minutes were counted twice
TIME COMBINATION RULES — ACP 2027
✅ ALLOWED
Practitioner time can help meet G-code threshold when staff time alone is insufficient
🚫 NEVER ALLOWED
Counting the same minutes toward multiple service codes
📋 DOCUMENT
Separate time logs for practitioner and staff — specific enough to survive audit
What supervision and documentation rules apply?
CMS finalized the new staff codes under direct supervision. The rule also confirms that direct supervision can be satisfied using audio-visual technology — a practical allowance for telehealth-era workflows.
Direct supervision confirmed
CMS declined to change the supervision framework to general supervision despite commenter requests.
The practical requirement is that the billing practitioner (or another qualifying practitioner) must be immediately available to assist the clinical staff during the ACP encounter.
For in-person settings, this typically means the supervising practitioner is in the same office suite. For virtual supervision, audio-visual technology must allow real-time interaction.
Staff qualifications
CMS did not prescribe a new national credential list for staff furnishing ACP under G0572/G0573. Applicable state requirements and the “incident to” rules govern which personnel can deliver the service.
A practice cannot assume that any staff member qualifies — but CMS also did not narrow the field beyond existing law.
Incident-to and the initiating visit question
CMS states ACP may be furnished incident to a physician’s services, subject to the applicable rules.
A prior visit for the patient’s diagnosis or treatment is presumed, but it is not required to occur on the same day as the ACP service. CMS did not finalize a same-day E/M visit requirement.
The distinction from the Annual Wellness Visit (AWV) pathway is important. ACP can be an optional part of the AWV, but AWV services may not be furnished incident to a physician’s professional services. Applying the incident-to analysis for standalone ACP to AWV-linked ACP would be an error.
Can ACP be billed through telehealth in 2027?
CMS added G0572 and G0573 to the Medicare Telehealth Services List beginning in CY 2027. Both codes are described as inherently face-to-face services that can be furnished through an interactive telecommunications system under applicable telehealth rules.
Listing the codes on the telehealth services list does not bypass other Medicare telehealth conditions. The practitioner, patient location, modality, and claim must all satisfy the telehealth requirements in effect for the date of service.
For practices that already deliver ACP via telehealth using 99497/99498, adding the G-codes to the telehealth list means clinical-staff ACP sessions can follow the same virtual delivery model — as long as direct supervision (via audio-visual technology) is maintained during the encounter.
What cost-sharing rules apply to ACP?
The 2027 rule changes coding and time attribution. It does not replace the existing Medicare ACP benefit structure.
ACP remains available through two pathways:
- As an optional AWV element (at the beneficiary’s discretion)
- As a separate medically necessary Part B service
When ACP is furnished on the same day as a covered AWV, by the same provider, and billed with modifier 33, the Part B deductible and coinsurance are waived. Separate ACP outside the AWV generally carries standard cost-sharing.
Consolidated billing rules apply to clinical-staff services in institutional settings — which means a facility-based practice should confirm billing responsibility before submitting the new G-codes.
What code-number conflict should billing teams verify?
The PFS final rule identifies G0572 and G0573 as ACP codes. However, a separate CMS final-rule publication’s code table also lists G0572/G0573 for dementia-management services.
The code-number collision needs reconciliation against the final 2027 HCPCS file or a CMS correction before the codes are used in live claims.
Billing teams should not activate edits or charge-capture rules for these codes until the conflict is resolved. Check the HCPCS code files, payer/MAC instructions, and any CMS errata or corrections published between November 2026 and January 2027.
The risk is small but real. Submitting a claim with a code that maps to two different services in different CMS publications could trigger edits, denials, or audit flags that take weeks to resolve.
What should practices update before January 2027?
The operational work comes down to separating time, updating systems, and verifying code assignments.
Separate Practitioner and Staff Time
Update EHR charge capture and time logs to record practitioner minutes separately from staff minutes.
Train Staff on Time-Combination Rules
Explain when practitioner and staff time may be combined, which activities qualify, and how to prevent double-counting.
Review AWV-Related ACP Billing
Add a review step for advance care planning (ACP) performed with an Annual Wellness Visit (AWV) to prevent incorrect use of incident-to billing rules.
Verify G0572 and G0573 Before Activation
Reconcile code descriptors against the 2027 HCPCS file and applicable payer and MAC instructions before adding the codes to billing systems.
Confirm Telehealth Supervision
Verify that the required direct supervision conditions can be met for ACP encounters delivered through telehealth.
Check Staff Qualifications
Confirm that staff meet applicable state-law qualifications and Medicare incident-to requirements for the services they perform.
Your billing team should not be guessing how to split ACP minutes
The 2027 ACP code split adds a new documentation and coding layer to every advance care planning encounter. Incorrect time attribution, missed supervision requirements, or unresolved code conflicts can turn a clean claim into a denial.
MedHeave’s AAPC-certified coders and billing teams work inside your EHR to handle the details.
- Credentialing management to prevent provider-level billing gaps
- Claim scrubbing before submission with payer-specific guideline checks
- Provider queries tracked through PM software and resolved within 72 hours
- Denial management with documented response windows and 80%+ overturn rate
- Coding accuracy reviews covering CPT, HCPCS, modifiers, and documentation linkage
Frequently asked questions
Here are some commonly asked questions on this topic:
CMS finalized G0572 (first 20 minutes of clinical-staff ACP time) and G0573 (each additional 20 minutes) for the 2027 performance period. Both codes describe ACP services — explanation and discussion of advance directives — furnished by clinical staff under the billing practitioner’s direct supervision. CPT codes 99497 and 99498 remain in use but are now limited to the billing practitioner’s personally spent time. The two code families can be reported together when each family’s time threshold is met.
Yes. Both code families may be reported when each has its own qualifying time. If a practitioner spends 30+ minutes and clinical staff spends 20+ minutes on ACP during the same encounter, the practitioner reports 99497 and the staff’s time is reported under G0572. Practitioner time can also be combined with staff time to meet the G-code threshold when staff time alone falls short. The same minutes cannot count toward more than one code.
CMS presumes a prior visit for the patient’s diagnosis or treatment, but it does not require that visit to occur on the same day as the ACP service. A practice can bill ACP on a day the patient does not have a separate E/M visit — provided the other ACP billing requirements (documentation, supervision, time thresholds) are met. The AWV pathway has different rules; AWV services may not be furnished incident to a physician’s professional services.
CMS added both codes to the Medicare Telehealth Services List for 2027. Clinical-staff ACP sessions can be delivered via interactive telecommunications systems, and direct supervision can be satisfied through audio-visual technology. However, telehealth listing alone does not guarantee that every claim meets all Medicare telehealth conditions — practitioner eligibility, patient location, and modality requirements still apply for the specific date of service.
Not automatically. The 2027 ACP provisions are Original Medicare PFS policy. Medicare Advantage plans, Medicaid programs, and commercial payers set their own coding and coverage rules. Some may adopt the new G-codes, others may not. Practices billing ACP to non-Original-Medicare payers should verify each plan’s coding and coverage policy before submitting claims with G0572 or G0573.
