FQHCs and RHCs Can Bill ACCESS Co-Management Claims Starting October 1

October 1, 2026 is the first date of service for ACCESS Co-Management Payments (CMP), according to CMS billing guidance. The guidance covers Medicare-enrolled federally qualified health centers and rural health clinics participating in the ACCESS Model. It describes how to submit claims; it does not mean every care-coordination activity is separately billable.

The central documentation check is whether an eligible practitioner reviewed an ACCESS care update and performed at least one qualifying coordination activity. CMS specifies a minimum total of five minutes for the service. The record should support the work, the date, the patient’s qualifying track, and the claim line.

Confirm the institutional claim path

CMS directs FQHCs and RHCs to submit institutional claims using the 837I or CMS-1450/UB-04 format. The guidance identifies Type of Bill 77X for FQHCs and 71X for RHCs. Confirm the organization’s enrollment and billing configuration before the first submission, including that the Type 2 organizational NPI is associated with the TIN in PECOS as CMS requires.

The track determines the service code: G0676 for eCKM or CKM, G0677 for musculoskeletal care, and G0678 for behavioral health. CMS specifies modifier AC for onboarding support. Check the current CMS guidance and contractor instructions for the complete claim requirements.

Use a first-claim checklist

Before releasing an October claim, billing and clinical operations can review the same small set of fields:

• Confirm the beneficiary and organization meet the ACCESS Model and billing eligibility requirements.
• Match the documented care update, coordination activity, track, qualifying diagnosis, and date of service.
• Use the correct Type of Bill, track-specific HCPCS code, and modifier when applicable.
• Report one unit per claim line and verify the applicable frequency limit; CMS states no more than three payments per beneficiary per track in a 12-month period.
• Retain the note and claim support needed to explain why the service met CMS’s time and activity criteria.

A short prebill review can catch mismatches between the care record and the institutional claim before they become denials or rework. Use CMS’s current billing guide as the source of truth, and confirm operational details with your Medicare Administrative Contractor where needed.

Keep the model rules in view

ACCESS is a CMS Innovation Center model focused on technology-supported care for people with certain chronic conditions. The co-management payment guidance is specific to participating organizations and defined care tracks. Practices should not treat the codes as general-purpose care-management billing or infer coverage beyond the published requirements.

For the October 1 start, align clinical documentation, enrollment, coding, and claim edits around the same CMS checklist. That gives the team a clear way to review the first claims and investigate any returned or denied lines.