26-1000 ECM Billing Limits Take Effect October 15, 2026

By October 15, 2026: Billing team must implement controls in billing software to enforce the 10-unit monthly limit on ECM claims and configure system to automatically deny claims exceeding this threshold. Providers must review service delivery practices to ensure only covered ECM activities are billed (e.g., care coordination, assessments, care plan management, referrals, appointment assistance). Stop billing non-covered services including physical transportation, housing navigation, medical care/prescribing, routine appointment accompaniment, and standalone interpretation services. Establish documentation protocols requiring providers to record: (1) time spent on each covered service, (2) ECM activity type, and (3) team member identification for each billable unit. Apply standard Medicare rounding rules when converting minutes to billable hours. Maintain all supporting documentation for audit requests. Train all ECM billing staff on the new monthly limit, covered versus non-covered activities, and documentation requirements. For claims denied due to exceeding the monthly limit, prepare appeal submissions with detailed service evidence, time documentation, and provider identification. Consequence: Claims exceeding 10 units per member per month will be automatically denied.