Programs / ACP
Advance Care Planning

Advance Care Planning

ACP Period: Calendar month (time-based) Source: CMS-1832-F (CY 2026 PFS Final Rule)

What it is

Advance Care Planning (ACP) is the face-to-face counseling and discussion of advance directives (e.g., a living will, healthcare proxy, POLST/MOLST) between a physician or qualified health professional and the patient, family member, or surrogate. It is voluntary for the patient.

ACP is time-based and billed in 30-minute increments. Per the CPT "more than half" time rule, each unit is reportable once the midpoint of its increment is met: 99497 at ≥ 16 minutes; 99498 at ≥ 46 minutes (willowbridge bills one 99498 a month). It may be furnished on the same day as, and in addition to, an E/M visit or the Annual Wellness Visit. willowbridge tracks each patient's last ACP and flags when a refresh is due.

Who qualifies

Codes & when to bill them

How the minutes add upBill 99497 for the first 30 minutes — reportable once the provider's own discussion time passes the midpoint at 16 minutes. Add 99498 at the next midpoint, 46 minutes. willowbridge bills one 99498 a month and bills ACP under the patient's PCP.

Each billable code, with the requirements that must be on file to bill it.

Documentation required every cycle

Each ACP encounter must show:

  1. Voluntary nature of the discussion noted in the record.
  2. Total time spent face-to-face on advance care planning (rounded to the minute).
  3. A discussion note summarizing what was addressed (code status, surrogate, goals of care, directive type).
  4. Directive type on file (POLST / MOLST / Advance Directive) appropriate to the patient's state, with the signed legal form uploaded.
  5. Billing practitioner sign-off.

Built-in patient consentwillowbridge exclusive

Every program ships with compliant, CY-2026 patient consent language — read verbatim into the in-app consent capture flow, captured with date + modality, and version-pinned to each claim, so the consent on file always matches the consent that was billed. No more chasing signatures or re-papering when the rule changes.