Care management consent policies

FRONT MATTER

Document control and contents

Document set

Canonical URIs resolve under https://www.torch-wellness.com/policies. All five policies are effective June 18, 2026; published versions are immutable per TW-CP-000 §14.

Contents

Review and approval

Each policy is reviewed annually and within 60 days of each Medicare Physician Fee Schedule final rule. Approval rests with the members of Torch Wellness, LLC; signature blocks appear at the end of each policy.

Torch Wellness, LLC · Care management consent policies

Front matter · v1.0

OVERVIEW

How the policy system works

Five documents govern consent for the four Medicare care management programs Torch Wellness furnishes on behalf of client practices. One common policy carries everything the programs share, so the same rule is never written four different ways. Four program policies carry only what is specific to each service: the codes a consent covers, the program description, eligibility, the required disclosures, and the approved consent script.

Structure of the set

TW-CP-000 Common Consent Provisions

Method and timing · the enrollment-call pathway · required disclosure floor · cost sharing variants (standard, QMB, FQHC, MA) · single-practitioner rule · withdrawal mechanics · dual documentation (platform + practice EHR) and 10-year retention · hosting and versioning · concurrency · FHIR Consent binding · BigQuery data model · platform enforcement

Each program policy is read together with TW-CP-000. Where a client practice imposes stricter requirements by contract, the stricter requirement controls.

The consent lifecycle

1. 01 Screen

   Torch staff screen and queue candidates; the billing practitioner confirms eligibility. Enrollment screening asks whether another practice already furnishes the same program.

2. 02 Disclose

   Staff read or closely paraphrase the approved script for the program, using the QMB or FQHC variant where it applies. Improvised disclosures are not permitted.

3. 03 Capture

   The routine pathway is a Torch enrollment call: the consent is documented in the platform at the time of the call (the consent date of record) with the data elements in TW-CP-000 §13, then entered in the practice EHR within two business days. The EHR is the medical record of record; the platform consent gates billing.

4. 04 Enforce

   The platform gates billing on consent: no time log, device supply period, or claim candidate exists without an active consent covering the date of service and matching billing practitioner (TW-CP-000 §18).

5. 05 Maintain

   No annual re-consent is required. Staff re-affirm enrollment about once a year during a routine monthly contact, recorded as a verification event; material disclosure changes are communicated at the next monthly contact.

6. 06 Close

   Withdrawal, through any channel and with no reason required, is effective at month end. A practitioner change closes the consent and opens re-consent. Records are retained at least ten years and never deleted.

Versioning and canonical URIs

The five policies are published together as one document at a stable, versioned URI. A published version is never edited; corrections create a new version at a new URI, and every consent record pins the exact version it was captured against.

https://www.torch-wellness.com/policies/consent/v{major}-{minor}

Minor versions cover editorial changes; major versions cover changes to disclosures, eligibility, or withdrawal mechanics. Existing consents remain valid under the version they were captured against.

Where consent lives in the platform

Consent is operational data, not paperwork. The Torch platform (app.torch-wellness.com) stores one row per program consent per enrollment span in the consents table, renders any consent as a FHIR R4 Consent resource with treatment scope, and writes every creation, revocation, practitioner change, and version migration to an append-only audit log. The practice EHR remains the medical record of record: every platform consent opens an EHR documentation task, completed within two business days and tracked to completion, with the note reference stored on the consent row. The enforcement rules the platform applies (consent gates, practitioner matching, the CCM/APCM exclusion, the G0570 dual gate, QMB suppression, RPM exclusivity, and EHR sync tracking) are specified in TW-CP-000 §16–18.

Torch Wellness, LLC · Care management consent policies

Overview · v1.0

COMPARISON

Programs at a glance

A working summary for staff. The program policies control; where this table and a policy differ, the policy governs.

Program snapshot

Cost sharing variants

Dollar amounts never appear in canonical policy text, only in bracketed script inserts, updated each January and on code-mix changes (TW-CP-000 §7.6).

Concurrency matrix

From TW-CP-000 §15. A minute counts toward one program only.

Torch Wellness, LLC · Care management consent policies

Comparison · v1.0

Common Consent Provisions for Care Management Programs

Policy ID

TW-CP-000

Version

1.0 (approved)

Effective date

June 18, 2026

Approved

June 12, 2026 — Holly Crawley, Pharm.D., BCPS, BCCCP (Director of Clinical Services); R. Monroe Crawley, Pharm.D., BCPS, BCCCP, CACP

Canonical URI

https://www.torch-wellness.com/policies/consent/v1-0

Owner

Torch Wellness, LLC

Applies to

TW-CP-001 (CCM), TW-CP-002 (APCM), TW-CP-003 (RPM), TW-CP-004 (BHI)

Review cycle

Annually, and within 60 days of each Medicare Physician Fee Schedule final rule

1. Purpose

This policy establishes the standards Torch Wellness follows when obtaining, documenting, maintaining, and acting on patient consent for Medicare care management programs furnished on behalf of client practices. The program policies (TW-CP-001 through TW-CP-004) contain the disclosures and scripts specific to each program. This document carries everything the programs share, so the same rule is never written four different ways.

2. Scope

This policy applies to all consent activity for Chronic Care Management (CCM), Advanced Primary Care Management (APCM), Remote Physiologic Monitoring (RPM), and Behavioral Health Integration (BHI) services furnished by Torch Wellness staff on behalf of client practices. Medicare requirements are the floor. Where a client practice imposes stricter requirements by contract, the stricter requirement controls.

3. Definitions

Billing practitioner. The physician or qualified health care professional at the client practice under whose billing number the care management service is reported.

Client practice. A practice, clinic, or health center that has contracted with Torch Wellness for care management services. Includes federally qualified health centers (FQHCs) where noted.

Clinical staff. Personnel, including Torch Wellness pharmacists and pharmacy technicians, furnishing care management services under the general supervision of the billing practitioner consistent with 42 CFR 410.26.

Program. One of CCM, APCM, RPM, or BHI as defined in the corresponding program policy.

QMB. A Qualified Medicare Beneficiary, for whom federal law prohibits collection of Medicare deductibles, coinsurance, and copayments.

4. Operating model

Torch Wellness furnishes care management as clinical staff (auxiliary personnel) of the billing practitioner, incident to the practitioner's professional services under 42 CFR 410.26. Consent therefore runs to the billing practitioner's program, not to Torch Wellness as a standalone provider. Every consent identifies the billing practitioner and the client practice by name, and identifies Torch Wellness as the care management team working on the practice's behalf. Patients are never asked to consent to Torch Wellness services in the abstract.

Two record systems are involved. The client practice's EHR is the medical record of record, and it is where CMS expects consent to be documented for billing. The Torch platform is the operational system: it holds the consent record that gates time logging and claim candidates, and it is where Torch staff document the verbal consents they obtain. Section 13 governs how the two stay in sync.

Initiating visits, Annual Wellness Visits, and IPPEs are furnished by the client practice. Torch's role begins with outreach, enrollment, and the between-visit services. Torch has the capability to furnish AWVs but does not do so routinely; if a client arrangement has Torch furnish them, this policy applies unchanged.

5. Method, timing, and who may obtain consent

5.1 Consent may be verbal or written. Medicare does not require a signature for any of the four programs. Verbal is the method of record by default: a documented consent is treated as obtained verbally unless a signed written consent has been noted and commented in the patient's chart, in which case the method of record is written. This default classifies the method of an existing consent record — it never substitutes for documenting the consent itself. Verbal consent is valid only when documented contemporaneously in the patient record with the data elements in Section 13.

5.2 Consent must be obtained before or at the initiation of services. For RPM, consent may be obtained at the time the service is furnished, before the first billable activity.

5.3 Consent may be obtained by the billing practitioner or by clinical staff, including Torch Wellness staff, using the approved script in the applicable program policy. Staff read or closely paraphrase the approved script. Improvised disclosures are not permitted.

5.4 Consent may be given by the patient or, where the patient lacks capacity or requests it, by a caregiver or legally authorized representative. The representative's name and relationship are documented.

5.5 The routine consent pathway is a Torch enrollment call. Staff reach the patient by phone, deliver the disclosures using the approved script, and document the consent in the platform at the time of the call. The date of that call is the consent date of record in the platform and sets the start of the enrollment period. This call occurs even when the client practice has already discussed or documented consent at a visit. In that case the call serves as an additional verbal consent: it confirms the disclosures, captures the documentation elements in Section 13, and notes the earlier practice consent if known. Billable Torch activity never begins before the platform consent date.

6. Required disclosure elements

Every program consent includes, at minimum:

1. That the service is available, with a plain language description of what it includes.
2. That Medicare cost sharing may apply, described per Section 7.
3. That only one practitioner can furnish and be paid for the service during a given period (calendar month for CCM, APCM, and BHI; 30-day period for RPM device supply).
4. That the patient may stop the service at any time, effective at the end of the calendar month, with no penalty and no effect on their other care.
5. That health information will be shared among the practitioners and clinical staff involved in the patient's care for coordination purposes.

Program policies add disclosures specific to each service. The combined set in each program policy is the complete required disclosure for that program.

7. Cost sharing standards

7.1 Standard Medicare Part B. The annual Part B deductible and 20 percent coinsurance apply and recur in each period the service is billed. Scripts disclose that the charge is recurring, not one time. Scripts use a bracketed insert for the current estimated monthly coinsurance for the base code. The insert is updated each January when the fee schedule changes and whenever the program's typical code mix changes.

7.2 Supplemental coverage. Scripts note that Medigap, Medicaid, or other secondary coverage often pays the cost sharing.

7.3 QMB patients. Federal law prohibits billing QMB patients for Medicare cost sharing. When the patient is a QMB, staff use the QMB variant paragraph in the script, the platform suppresses all patient responsibility statements and collection tasks for that patient, and the eligibility evidence (HETS response, 271, or a remittance showing QMB status) is retained. This rule applies at every client practice, not only FQHCs.

7.4 FQHC client practices. The Medicare Part B deductible does not apply to FQHC services. At FQHC clients, scripts omit deductible language and disclose the 20 percent coinsurance only. QMB handling under 7.3 is unchanged.

7.5 Medicare Advantage. MA plans cover these services with plan-specific cost sharing. Scripts state that the patient's plan rules determine the amount and direct detailed questions to the plan.

7.6 Dollar amounts never appear in the canonical policy text, only in the bracketed script inserts, so a fee schedule update does not force a policy version change.

8. Single billing practitioner rule and practitioner changes

8.1 Only one practitioner may bill a given program for a patient in a period. Enrollment screening asks whether another practice is already furnishing the same program and documents the answer.

8.2 A change in billing practitioner requires a new consent before any further billable activity under the new practitioner. The platform closes the prior consent (period end set to the change date) and opens the re-consent workflow. This applies whether the change is within the same practice or across practices, and it applies when a patient moves between programs that CMS treats as requiring fresh consent, such as moving from CCM to APCM.

9. Withdrawal of consent

9.1 A patient may withdraw at any time, through any channel, verbally or in writing, with no penalty. Staff never require a reason, though one may be recorded if offered.

9.2 Withdrawal is effective at the end of the calendar month in which it is received. Services furnished through the effective date remain billable. For RPM, a 30-day device supply period whose requirements were already met before the effective date may be billed, and device return follows TW-CP-003 Section 9.

9.3 Withdrawal from one program does not affect the patient's other enrollments unless the patient says otherwise. Staff confirm scope at the time of withdrawal (for example, "Are you stopping just the monitoring program, or the monthly care management as well?") and document the answer.

10. Duration and renewal

Consent remains in effect until the patient withdraws, the patient becomes ineligible or dies, the program ends at the client practice, or the billing practitioner changes. CMS does not require annual re-consent and this policy does not impose one. As a best practice, staff re-affirm enrollment about once a year during a routine monthly contact. Re-affirmation is recorded as a verification event on the existing consent, not as a new consent. AWVs are furnished by the client practices; if consent comes up at an AWV, the practice documents that discussion in its EHR, and it does not replace or reset the platform record.

A material change to the required disclosures (for example, a CMS rule change that alters the cost sharing description) is communicated to enrolled patients at the next monthly contact and documented. Routine editorial changes to policy text do not require patient notification.

11. Information sharing

11.1 Sharing patient information among the billing practitioner, other treating providers, and clinical staff for these programs is treatment, payment, and health care operations under HIPAA and does not require a separate authorization. The consent disclosure in Section 6, item 5, is a CMS program requirement and a courtesy to the patient, not the legal basis for the sharing.

11.2 For CCM and APCM, the electronic care plan is shared within and outside the practice as needed for coordination, and the patient receives a copy.

11.3 Behavioral health information handled under TW-CP-004 receives the same protections as all other PHI, with two cautions. First, if records are received from a federally assisted substance use disorder treatment program, 42 CFR Part 2 restricts redisclosure of those records, and they are segregated and flagged in the platform. Second, staff do not read behavioral health details into voicemails or share them with family members absent patient direction. Counsel should review this section before deployment.

12. Language access and capacity

Consent is obtained in a language the patient understands, using qualified interpretation when needed, and the language and any interpreter use are documented. If staff have reason to doubt the patient's capacity to consent, the billing practitioner is consulted and consent is sought from an authorized representative per Section 5.4.

13. Documentation and retention

13.1 Every consent record captures, at minimum: patient identity, client practice, program, date and time, method (verbal or written), who obtained it, consenting party (patient or representative with name and relationship), billing practitioner, the policy URI and version in effect, the script version read, the patient's response, QMB status at capture, and the date of any consent the practice separately documented, if known. Written consents also attach the signed form.

13.2 Every consent is documented in both systems. Torch staff record the consent in the platform at the time of the call, then enter a consent note in the practice EHR directly when Torch has EHR access, or transmit the note to the practice for filing when it does not. The EHR entry is completed within two business days of the call, and the platform stores the EHR note reference and the date it was entered. An outstanding EHR entry does not block billable activity, but the platform flags any entry pending past two business days until it is resolved.

13.3 Consent records, withdrawal records, and the eligibility evidence in 7.3 are retained in the platform at least ten years, matching the False Claims Act lookback, or longer where a client practice contract requires. Retention in the practice EHR follows the practice's own policy.

14. Policy hosting, URIs, and versioning

14.1 The five policies are published together as one document at a stable, versioned URI:

https://www.torch-wellness.com/policies/consent/v{major}-{minor}

The consent record’s program code identifies which policy within the document applies. The production domain is www.torch-wellness.com; the platform configuration and all five documents use it.

14.2 A published version is never edited. Corrections and changes create a new version at a new URI. A human-friendly redirect such as /policies/consent/current may exist, but consent records always store the explicit versioned URI.

14.3 Minor versions (1.1, 1.2) cover editorial changes that do not alter required disclosures. Major versions (2.0) cover changes to disclosures, eligibility, or withdrawal mechanics. Existing consents remain valid under the version they were captured against. The platform records which version each consent points to and supports reporting by version.

15. Program concurrency rules

16. FHIR Consent binding

Consent records follow FHIR R4 Consent with treatment scope. Whether stored natively or projected from the BigQuery table in Section 17, the platform must be able to render any consent in this shape.

{
    "resourceType": "Consent",
    "status": "active",
    "scope": {
      "coding": [{
      "system": "http://terminology.hl7.org/CodeSystem/consentscope",
      "code": "treatment"
      }]
   },
   "category": [
      { "coding": [{ "system": "http://loinc.org", "code": "59284-0", "display": "Patient Consent"
}] },
      { "coding": [{ "system": "https://torch-wellness.com/fhir/CodeSystem/consent-program",
"code": "ccm" }] }
   ],
   "patient": { "reference": "Patient/{patient-id}" },
   "dateTime": "2026-09-01T10:15:00-05:00",
   "performer": [{ "reference": "Practitioner/{torch-staff-id}" }],
   "organization": [{ "reference": "Organization/{client-practice-id}" }],
   "sourceReference": { "reference": "DocumentReference/{note-or-signed-form-id}" },
   "policy": [{ "uri": "https://www.torch-wellness.com/policies/consent/v1-0" }],
   "policyRule": {
      "coding": [{ "system": "http://terminology.hl7.org/CodeSystem/v3-ActCode", "code": "OPTIN"
}]
   },
   "verification": [{
      "verified": true,
      "verifiedWith": { "reference": "Patient/{patient-id}" },
      "verificationDate": "2026-09-01"
   }],
   "provision": {
      "type": "permit",
      "period": { "start": "2026-09-01" },
      "actor": [{
         "role": { "coding": [{ "system": "http://terminology.hl7.org/CodeSystem/v3-ParticipationType", "code": "PRF" }] },
         "reference": { "reference": "Practitioner/{billing-practitioner-id}" }
      }],
      "purpose": [
         { "system": "http://terminology.hl7.org/CodeSystem/v3-ActReason", "code": "TREAT" },
         { "system": "http://terminology.hl7.org/CodeSystem/v3-ActReason", "code": "CAREMGT" }
      ],
      "code": [
         { "coding": [{ "system": "http://www.ama-assn.org/go/cpt", "code": "99490" }] }
      ]
   }
}

Implementation notes:

• The local code system consent-program carries codes ccm, apcm, rpm, and bhi. Host its definition alongside the policies.
• provision.code lists the billable codes covered by the consent, per the binding table in each program policy. CPT codes use the AMA system URI shown above. G codes use https://www.cms.gov/Medicare/Coding/HCPCSReleaseCodeSets.
• On withdrawal, set status to inactive and provision.period.end to the last day of the effective month. Never delete.
• TREAT is the anchor purpose code. CAREMGT is included for specificity. If a downstream validator rejects it, drop it rather than substituting a different code.

17. Platform data model (BigQuery)

Suggested consents table. One row per program consent per enrollment span. Revocation updates the row. A practitioner change closes the row and creates a new one.

18. Platform enforcement requirements

The platform enforces, not merely records, the following:

1. Consent gate. No time log, device supply period, or claim candidate is created for a program without an active consent for that program whose period covers the date of service.
2. Practitioner match. The billing practitioner on a claim candidate must equal billing_practitioner_id on the governing consent. A mismatch blocks the claim and opens the re-consent task.
3. CCM and APCM exclusion. A patient cannot hold active CCM and APCM consents at the same time.
4. G0570 dual gate. A G0570 claim candidate requires an active APCM consent, an active BHI consent, and an APCM base code in the same month for the same practitioner.
5. Revocation handling. Sets status to inactive and period_end to the last day of the current month. Billable activity is permitted through period_end and blocked after.
6. QMB suppression. QMB status suppresses patient responsibility statements and collection tasks and pins the QMB script variant in the consent workflow.
7. Version pinning. Every consent stores its policy_uri and script_version. Published versions are immutable.
8. RPM exclusivity. One device supply code (99445 or 99454) per patient per 30-day period. One management track (99470, or 99457 with optional 99458) per calendar month.
9. Audit trail. Consent creation, revocation, practitioner change, and version migrations write to an append-only log.
10. EHR sync tracking. Every platform consent opens an EHR documentation task that records the practice EHR note reference and completion date. The platform flags any task pending more than two business days. The consent gate in rule 1 keys on the platform consent, not on the EHR task.

Approval

Torch Wellness, LLC · Common Consent Provisions

TW-CP-000 · v1.0

Chronic Care Management (CCM) Consent Policy

Policy ID

TW-CP-001

Version

1.0 (approved)

Effective date

June 18, 2026

Approved

June 12, 2026 — Holly Crawley, Pharm.D., BCPS, BCCCP (Director of Clinical Services); R. Monroe Crawley, Pharm.D., BCPS, BCCCP, CACP

Canonical URI

https://www.torch-wellness.com/policies/consent/v1-0

FHIR program code

ccm

Governing framework

TW-CP-000 Common Consent Provisions

Owner

Torch Wellness, LLC

1. Purpose and scope

This policy governs patient consent for Chronic Care Management services furnished by Torch Wellness on behalf of client practices. Read it together with TW-CP-000, which controls consent method, documentation, withdrawal mechanics, cost sharing variants, retention, and platform enforcement.

Codes covered by a CCM consent:

The platform code repository remains the authoritative source for rates and code status. This table defines what the consent covers.

2. Program description

CCM provides structured, between-visit care for patients managing multiple chronic conditions: a comprehensive, patient-centered care plan that the patient receives a copy of and that is shared electronically with the care team; at least 20 minutes per month of clinical staff care management, delivered primarily by Torch Wellness pharmacists and pharmacy technicians; medication management and refill coordination; coordination across treating providers and during transitions of care; and 24/7 access to a clinician for urgent needs.

3. Eligibility

Two or more chronic conditions expected to last at least 12 months or until the death of the patient, that place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline. Typical qualifying conditions include diabetes, hypertension, heart failure, COPD, chronic kidney disease, atrial fibrillation, and depression. The billing practitioner confirms eligibility. Torch staff screen and queue candidates.

Under the Torch service hierarchy, patients who meet CCM criteria are enrolled in CCM rather than APCM. See TW-CP-002 Section 3.

4. Initiating visit

New patients, and patients not seen by the billing practitioner within the past 12 months, require an initiating visit (an E/M visit, Annual Wellness Visit, or IPPE) before CCM begins, with CCM discussed at that visit. Initiating visits are furnished by the client practice. The practice may discuss and document consent at the visit; in the routine workflow, Torch then obtains and documents its own verbal consent by phone per Section 5. G0506 may be billed with the initiating visit when the practitioner personally performs assessment and care planning beyond the usual work of the visit.

5. Consent requirements

Consent is obtained before or at the start of CCM, verbal or written, by the billing practitioner or clinical staff per TW-CP-000 Section 5. The routine pathway is a Torch enrollment call: staff reach the patient by phone, read the script in Section 7, and document the consent in the platform at the time of the call. The date of that call is the consent date of record in the platform and the start of the enrollment period, even when the practice has already discussed or documented consent at a visit; the earlier practice consent is noted in the record if known. The consent is also entered in the practice EHR per TW-CP-000 Section 13. A new consent is required if the billing practitioner changes (TW-CP-000 Section 8.2) and if the patient later moves to APCM.

6. Required disclosures

Each item must be communicated before consent is accepted:

1. CCM is available to the patient, with a plain description of the services in Section 2.
2. Medicare cost sharing applies and recurs monthly: the Part B deductible and 20 percent coinsurance. QMB and FQHC variants per TW-CP-000 Section 7.
3. Only one practitioner can furnish and be paid for CCM during a calendar month.
4. The patient may stop CCM at any time, effective at the end of that calendar month.
5. The patient's health information, including the electronic care plan, will be shared among the providers and clinical staff involved in their care, and the patient will receive a copy of the care plan.

7. Approved verbal consent script (v1.0)

Brackets are completed by the speaker. Read naturally. Do not skip required items.

SCRIPT: READ VERBATIM OR CLOSELY PARAPHRASE

"Hi [patient first name], this is [staff name]. I'm a [pharmacist / pharmacy technician] on the care management team that works with [billing practitioner] at [practice name]. [He/She] asked us to reach out about a Medicare program called Chronic Care Management. Do you have a couple of minutes for me to explain it?

You qualify because you're managing more than one ongoing health condition. Here's what the program includes. We build a written care plan with you and keep it up to date, and you get your own copy. Someone from our team checks in with you by phone each month. We help with your medications and refills, and we coordinate with all of your doctors so nothing slips through the cracks between visits. You also get a number where you can reach a clinician any time, day or night, if something urgent comes up.

Medicare covers this. Like most Part B services, your deductible and a 20 percent coinsurance apply, and because this is a monthly program, that's a monthly charge while you're enrolled. For the base service it usually comes to about [current estimate] a month. If you have a Medicare supplement or Medicaid, it often picks that up.

A few things Medicare requires me to tell you. Only one practice can bill for this program in a given month, so please let me know if another office is already doing chronic care management with you. You can stop at any time just by telling us, and it would end at the close of that month. And to coordinate your care, we share your health information, including your care plan, with the other providers who treat you.

Would you like to enroll in the program with [billing practitioner]'s office?"

QMB variant. Replace the cost sharing paragraph with: "Medicare covers this, and because your Medicaid coverage pays your Medicare cost sharing, you will not be billed a deductible or coinsurance for this program. There's no out of pocket cost to you."

FQHC client practices. Omit the deductible language and disclose the 20 percent coinsurance only, per TW-CP-000 Section 7.4.

Documentation block. Record in the platform at the time of the call: date and time; method (verbal); who obtained consent; consenting party and, if a representative, name and relationship; billing practitioner; the patient's response; script version TW-CP-001 v1.0; QMB status at capture; and the date of any consent the practice already documented, if known. The platform consent form captures these fields. Then enter the consent note in the practice EHR per TW-CP-000 Section 13.2.

8. Written consent

A written consent form, when used, contains every disclosure in Section 6 in substantially the script's language, plus signature and date, and the same documentation fields. The signed form is attached to the consent record as the source document.

9. Withdrawal

Per TW-CP-000 Section 9. Withdrawal is effective at the end of the calendar month in which it is received. That month's CCM time remains billable if thresholds are met.

10. Concurrency

CCM may be billed in the same month as BHI (99484) and RPM, with no minute counted toward more than one program. CCM is never active alongside APCM for the same patient. TCM in the same month is permitted only when both services' requirements are independently met and no time is double counted. See TW-CP-000 Section 15.

11. FHIR binding

Approval

Torch Wellness, LLC · CCM Consent Policy

TW-CP-001 · v1.0

Advanced Primary Care Management (APCM) Consent Policy

Policy ID

TW-CP-002

Version

1.0 (approved)

Effective date

June 18, 2026

Approved

June 12, 2026 — Holly Crawley, Pharm.D., BCPS, BCCCP (Director of Clinical Services); R. Monroe Crawley, Pharm.D., BCPS, BCCCP, CACP

Canonical URI

https://www.torch-wellness.com/policies/consent/v1-0

FHIR program code

apcm

Governing framework

TW-CP-000 Common Consent Provisions

Owner

Torch Wellness, LLC

1. Purpose and scope

This policy governs patient consent for Advanced Primary Care Management services furnished by Torch Wellness on behalf of client practices. Read it together with TW-CP-000, which controls consent method, documentation, withdrawal mechanics, cost sharing variants, retention, and platform enforcement.

Codes covered by an APCM consent:

G0568 and G0569, the Collaborative Care Model add-ons created for 2026, exist in the code set but are outside Torch's current service scope. See TW-CP-004 Section 1. G0570 claims are additionally governed by TW-CP-004 and require an active BHI consent.

The platform code repository remains the authoritative source for rates and code status. This table defines what the consent covers.

2. Program description

APCM is Medicare's monthly bundled primary care management service. There is no minute threshold. Instead, the practice makes the 13 APCM service elements available each month: 24/7 access to the care team, continuity with a designated team, comprehensive care management, an electronic patient-centered care plan that the patient receives a copy of, management of care transitions, coordination of referrals and community services, ongoing communication including digital channels, population-level data review, and risk stratification, among them. Torch Wellness operates these elements on the practice's behalf as clinical staff.

3. Eligibility and program placement

Medicare does not restrict APCM by condition count. Any consenting patient is eligible, with the billing level set by condition count and QMB status: level 1 for zero or one chronic condition, level 2 for two or more, level 3 for two or more with QMB status.

Under the Torch service hierarchy, APCM is the placement for patients who do not meet CCM's two-condition criteria or for whom monthly time-based engagement is not expected. Patients who meet CCM criteria are enrolled in CCM. A patient is never enrolled in both.

The practitioner billing APCM assumes responsibility for the patient's primary care and serves as the continuing focal point for the patient's health care services. This expectation is disclosed to the patient as part of consent.

4. Initiating visit

New patients, and patients not seen within the past three years, require an initiating visit before APCM begins. Qualifying visits include E/M levels 2 through 5 (99212 through 99215), the TCM face-to-face visit, the Annual Wellness Visit, and the IPPE, provided APCM is discussed during the visit. Initiating visits are furnished by the client practice. The practice may discuss and document consent at the visit; in the routine workflow, Torch then obtains and documents its own verbal consent by phone per Section 5. The visit also establishes that subsequent care management may be performed by auxiliary personnel, including Torch staff, under the practitioner's supervision.

5. Consent requirements

Consent is obtained before or at initiation, verbal or written, by the billing practitioner or clinical staff per TW-CP-000 Section 5. The routine pathway is a Torch enrollment call: staff reach the patient by phone, read the script in Section 7, and document the consent in the platform at the time of the call. The date of that call is the consent date of record in the platform and the start of the enrollment period, even when the practice has already discussed or documented consent at a visit; the earlier practice consent is noted in the record if known. The consent is also entered in the practice EHR per TW-CP-000 Section 13. APCM consent is separate from any prior CCM or PCM consent: a patient moving from CCM to APCM gives a new APCM consent, and the platform closes the CCM consent. A new consent is also required on a change of billing practitioner.

6. Required disclosures

Each item must be communicated before consent is accepted:

1. APCM is available to the patient, with a plain description of the services in Section 2.
2. The practitioner intends to take responsibility for the patient's primary care and to serve as the ongoing focal point for their health care.
3. Medicare cost sharing may apply and recurs monthly. QMB and FQHC variants per TW-CP-000 Section 7. Level 3 (G0558) patients are by definition QMBs, so the QMB variant is always used for them.
4. Only one practitioner can furnish and be paid for APCM during a calendar month, and APCM is not billed in the same month as chronic care management, principal care management, or transitional care management for the patient.
5. The patient may stop at any time, effective at the end of the calendar month.
6. Health information, including the care plan, is shared among the care team for coordination, and the patient receives a copy of the care plan.
7. When behavioral health support is added under G0570, it carries its own monthly cost sharing, and the BHI disclosures in TW-CP-004 are given before the add-on begins.

7. Approved verbal consent script (v1.0)

Brackets are completed by the speaker. Read naturally. Do not skip required items.

SCRIPT: READ VERBATIM OR CLOSELY PARAPHRASE

"Hi [patient first name], this is [staff name] from the care management team that works with [billing practitioner] at [practice name]. [He/She] would like to enroll you in a Medicare program called Advanced Primary Care Management. Can I take two minutes to walk you through it?

The idea is simple: [practice name] becomes your home base for health care. [Billing practitioner] takes responsibility for coordinating all of your primary care, and our team supports that between visits. You get a written care plan and your own copy of it, a way to reach the care team around the clock for urgent concerns, help when you leave a hospital or see a specialist, and regular contact from us so we stay ahead of problems instead of chasing them.

Medicare covers this as a monthly service. Your Part B deductible and a 20 percent coinsurance apply, which for this program usually comes to about [current estimate] a month, and a Medicare supplement or Medicaid often pays it.

A few required items. Only one practice can bill Medicare for this kind of care management in a month, and this program takes the place of chronic care management billing rather than stacking on top of it, so tell me if another office is managing your care this way. You can stop at any time, effective at the end of that month. And we share your health information, including your care plan, among the providers involved in your care so everyone works from the same page.

Would you like to enroll with [billing practitioner]?"

QMB variant. Replace the cost sharing paragraph with: "Medicare covers this, and because your Medicaid coverage pays your Medicare cost sharing, you will not be billed a deductible or coinsurance for this program. There's no out of pocket cost to you." This variant is mandatory for any patient enrolled at level 3 (G0558).

FQHC client practices. Omit the deductible language and disclose the 20 percent coinsurance only, per TW-CP-000 Section 7.4.

Documentation block. Record in the platform at the time of the call: date and time; method (verbal); who obtained consent; consenting party and, if a representative, name and relationship; billing practitioner; the patient's response; script version TW-CP-002 v1.0; QMB status at capture; and the date of any consent the practice already documented, if known. The platform consent form captures these fields. Then enter the consent note in the practice EHR per TW-CP-000 Section 13.2.

8. Written consent

A written consent form, when used, contains every disclosure in Section 6 in substantially the script's language, plus signature and date, and the same documentation fields. The signed form is attached to the consent record as the source document.

9. Withdrawal

Per TW-CP-000 Section 9. Withdrawal is effective at the end of the calendar month in which it is received. That month remains billable.

10. Concurrency

APCM is not billed in the same month as CCM, PCM, or TCM for the same patient, and the platform blocks dual CCM and APCM enrollment outright. RPM may run alongside APCM. BHI alongside APCM is billed as G0570 by the same practitioner in the same month, never as 99484. See TW-CP-000 Section 15.

11. FHIR binding

A G0570 claim candidate requires this consent and an active BHI consent (TW-CP-004) for the same patient and practitioner. See TW-CP-000 Section 18, rule 4.

Approval

Torch Wellness, LLC · APCM Consent Policy

TW-CP-002 · v1.0

Remote Physiologic Monitoring (RPM) Consent Policy

Policy ID

TW-CP-003

Version

1.0 (approved)

Effective date

June 18, 2026

Approved

June 12, 2026 — Holly Crawley, Pharm.D., BCPS, BCCCP (Director of Clinical Services); R. Monroe Crawley, Pharm.D., BCPS, BCCCP, CACP

Canonical URI

https://www.torch-wellness.com/policies/consent/v1-0

FHIR program code

rpm

Governing framework

TW-CP-000 Common Consent Provisions

Owner

Torch Wellness, LLC

1. Purpose and scope

This policy governs patient consent for Remote Physiologic Monitoring services furnished by Torch Wellness on behalf of client practices. Read it together with TW-CP-000, which controls consent method, documentation, withdrawal mechanics, cost sharing variants, retention, and platform enforcement.

Codes covered by an RPM consent:

99445 and 99454 are mutually exclusive within a 30-day period. 99470 and 99457 are mutually exclusive within a calendar month, and 99458 attaches only to 99457. The platform code repository remains the authoritative source for rates and code status. This table defines what the consent covers.

2. Program description

The patient receives a connected device, for example a blood pressure cuff, scale, glucometer, or pulse oximeter, that transmits readings automatically. Manually reported values do not qualify. The care team reviews the data, contacts the patient at least monthly by phone or video, flags concerning trends to the billing practitioner, and adjusts the plan under the practitioner's direction. RPM is monitoring and management, not emergency response.

3. Eligibility and clinical requirements

An established patient of the billing practitioner with a chronic or acute condition for which physiologic monitoring will inform treatment. The practitioner orders RPM and documents medical necessity. The device must meet the FDA definition of a medical device and transmit data automatically. 99453 is billable once per episode of care.

4. Consent requirements

Consent may be obtained at the time the service is furnished, before the first billable activity, which in practice means at or before device setup. Verbal or written, by the billing practitioner or clinical staff per TW-CP-000 Section 5. The routine pathway is a Torch phone call ahead of or at device setup: staff read the script in Section 6 and document the consent in the platform at the time of the call. The date of that call is the consent date of record in the platform and the start of the enrollment period, even when the practice has already discussed monitoring at a visit; the earlier practice consent is noted in the record if known. The consent is also entered in the practice EHR per TW-CP-000 Section 13. A new consent is required on a change of billing practitioner.

5. Required disclosures

Each item must be communicated before consent is accepted:

1. RPM is available to the patient, with a description of the device, the automatic transmission, who reviews the data, and how concerns are escalated.
2. The reading expectation: at least 16 days of readings in each 30-day period for full device-supply billing, with readings on most days as the clinical goal. Periods with 2 to 15 days of data are billable under the 2026 rules, so partial months may still generate a charge.
3. Medicare cost sharing applies and recurs. Most months include a device supply charge and a management charge, each subject to the Part B deductible and 20 percent coinsurance. QMB and FQHC variants per TW-CP-000 Section 7.
4. Only one practitioner can bill for device supply in a 30-day period, and only one device supply code is billable per patient per period no matter how many devices the patient uses.
5. The patient may stop at any time, effective at the end of the calendar month, with device return per Section 9.
6. Readings become part of the medical record and are shared with the care team for coordination.
7. The service is not for emergencies. For chest pain, severe symptoms, or anything that feels like an emergency, the patient calls 911.

6. Approved verbal consent script (v1.0)

Brackets are completed by the speaker. Read naturally. Do not skip required items.

SCRIPT: READ VERBATIM OR CLOSELY PARAPHRASE

"Hi [patient first name], this is [staff name] from the care management team that works with [billing practitioner] at [practice name]. [He/She] has ordered remote monitoring for your [condition], and I'd like to explain how it works and get your okay to start.

We'll set you up with a [device], and it sends your readings to us automatically. There's nothing to write down or call in. Our team watches those readings, and at least once a month we'll talk with you by phone about how things are trending. If we see something concerning, we flag it to [billing practitioner] right away. Your readings go into your chart and are shared with the providers involved in your care. To get the most out of the program, we ask you to take a reading on most days, at least 16 days a month.

One thing to be clear about: this is monitoring, not an emergency service. If you ever have chest pain, trouble breathing, or anything that feels like an emergency, call 911 first.

Medicare covers the program. Your Part B deductible and a 20 percent coinsurance apply, and because there's usually a monthly charge for the device and a separate one for our management time, you'd typically see about [current estimate] a month in coinsurance unless a supplement or Medicaid covers it. Also, only one practice can bill Medicare for monitoring you in a given period, so let me know if you're already on a monitoring program somewhere else.

You can stop any time by telling us. It would end at the close of that month, and we'd arrange for the device to come back to us.

Do we have your permission to start the monitoring program with [billing practitioner]?"

QMB variant. Replace the cost sharing paragraph with: "Medicare covers the program, and because your Medicaid coverage pays your Medicare cost sharing, you will not be billed a deductible or coinsurance for it. There's no out of pocket cost to you. Only one practice can bill Medicare for monitoring you in a given period, so let me know if you're already on a monitoring program somewhere else."

FQHC client practices. Omit the deductible language and disclose the 20 percent coinsurance only, per TW-CP-000 Section 7.4.

Documentation block. Record in the platform at the time of the call: date and time; method (verbal); who obtained consent; consenting party and, if a representative, name and relationship; billing practitioner; the patient's response; script version TW-CP-003 v1.0; QMB status at capture; the date of any consent the practice already documented, if known; and at setup, the device type and serial or asset number. The platform consent form captures these fields. Then enter the consent note in the practice EHR per TW-CP-000 Section 13.2.

7. Written consent

A written consent form, when used, contains every disclosure in Section 5 in substantially the script's language, plus signature and date, and the same documentation fields. The signed form is attached to the consent record as the source document.

8. Withdrawal

Per TW-CP-000 Section 9. Withdrawal is effective at the end of the calendar month in which it is received. A 30-day device supply period whose requirements were already met before the effective date may be billed.

9. Device return

The patient returns the device within 14 days of program end using the prepaid mailer or a clinic drop-off. The device remains the property of [Torch Wellness or the client practice, per contract]. No charge is made for normal wear. Return logistics and any lost-device terms are business terms set in each client contract. The brackets here are placeholders, not policy.

10. Concurrency

RPM runs alongside CCM, APCM, or BHI with time tracked separately. One device supply code per patient per 30-day period. One management track per calendar month. Remote Therapeutic Monitoring is outside Torch's service scope. See TW-CP-000 Section 15.

11. FHIR binding

Approval

Torch Wellness, LLC · RPM Consent Policy

TW-CP-003 · v1.0

Behavioral Health Integration (BHI) Consent Policy

Policy ID

TW-CP-004

Version

1.0 (approved)

Effective date

June 18, 2026

Approved

June 12, 2026 — Holly Crawley, Pharm.D., BCPS, BCCCP (Director of Clinical Services); R. Monroe Crawley, Pharm.D., BCPS, BCCCP, CACP

Canonical URI

https://www.torch-wellness.com/policies/consent/v1-0

FHIR program code

bhi

Governing framework

TW-CP-000 Common Consent Provisions

Owner

Torch Wellness, LLC

1. Purpose and scope

This policy governs patient consent for general Behavioral Health Integration services furnished by Torch Wellness on behalf of client practices. Read it together with TW-CP-000, which controls consent method, documentation, withdrawal mechanics, cost sharing variants, retention, and platform enforcement.

Codes covered by a BHI consent:

The Collaborative Care Model family (99492, 99493, 99494, G2214, and the 2026 APCM add-ons G0568 and G0569) is present in the platform code repository for reference but outside Torch's current service scope, since CoCM requires a designated behavioral health care manager and a psychiatric consultant. This policy covers the general BHI pathway only. The platform code repository remains the authoritative source for rates and code status. This table defines what the consent covers.

2. Program description

BHI brings behavioral health support into the primary care relationship. The team performs an initial assessment using validated instruments (PHQ-9 and GAD-7 are the Torch standards, with others as clinically indicated), builds a care plan with the patient, monitors symptoms with repeat instruments, supports medication management and adherence, coordinates referrals to counseling or psychiatry when needed, and keeps care continuous between visits. Pharmacist involvement centers on the medication side: initiation support, titration follow-up, side effect monitoring, and adherence.

3. Eligibility

A behavioral health or psychiatric condition, new or pre-existing, that in the billing practitioner's clinical judgment warrants BHI, including conditions identified by screening, for example a positive PHQ-9. A validated rating scale is administered at initiation and used for ongoing monitoring.

4. Initiating visit

New patients, and patients not seen by the billing practitioner within the past 12 months, require an initiating visit before BHI begins, as with CCM. Initiating visits are furnished by the client practice.

5. Consent requirements

Consent is obtained before or at initiation, verbal or written, by the billing practitioner or clinical staff per TW-CP-000 Section 5. The routine pathway is a Torch enrollment call: staff reach the patient by phone, read the script in Section 7, and document the consent in the platform at the time of the call. The date of that call is the consent date of record in the platform and the start of the enrollment period, even when the practice has already discussed or documented consent at a visit; the earlier practice consent is noted in the record if known. The consent is also entered in the practice EHR per TW-CP-000 Section 13. When BHI is added for a patient enrolled in APCM, the BHI consent is captured separately and the service is billed as G0570. The platform requires both consents before a G0570 claim candidate exists. A new consent is required on a change of billing practitioner.

6. Required disclosures

Each item must be communicated before consent is accepted:

1. BHI is available to the patient, with a plain description of the services in Section 2.
2. Medicare cost sharing applies and recurs monthly. QMB and FQHC variants per TW-CP-000 Section 7.
3. Only one practitioner can furnish and be paid for BHI during a calendar month.
4. The patient may stop at any time, effective at the end of the calendar month.
5. Behavioral health information will be shared among the practitioners and clinical staff involved in the patient's care for coordination, with the protections in TW-CP-000 Section 11.3.
6. BHI is not a crisis service. In a mental health emergency the patient calls or texts 988, or calls 911.

7. Approved verbal consent script (v1.0)

Brackets are completed by the speaker. Read naturally. Do not skip required items.

SCRIPT: READ VERBATIM OR CLOSELY PARAPHRASE

"Hi [patient first name], this is [staff name] from the care management team that works with [billing practitioner] at [practice name]. [He/She] would like to add some structured support for your [mood / anxiety / behavioral health], alongside the rest of your care. Can I explain what that looks like?

We start with a short questionnaire, the same kind you may have done in the office, to get a clear baseline. From there we build a plan with you, check in regularly, and repeat the questionnaire from time to time so we can actually see whether things are improving. A big part of my role is the medication side: if [billing practitioner] starts or adjusts something, I follow up on how it's working and any side effects. If counseling or a specialist would help, we coordinate that referral.

Everything stays inside your care team. We share this information with the providers involved in your care so your treatment is coordinated, and we treat it with the same privacy protections as the rest of your record.

Medicare covers this as a monthly service, so your Part B deductible and a 20 percent coinsurance apply each month it's provided, usually about [current estimate], and a Medicare supplement or Medicaid often pays it. Only one practice can bill Medicare for this service in a given month. And you can stop any time by telling us. It would end at the close of that month.

One more thing, and it matters: this program is support between visits, not a crisis line. If you're ever in a mental health emergency, call or text 988, or call 911.

Would you like to get started with [billing practitioner]'s office?"

QMB variant. Replace the cost sharing paragraph with: "Medicare covers this as a monthly service, and because your Medicaid coverage pays your Medicare cost sharing, you will not be billed a deductible or coinsurance for it. There's no out of pocket cost to you. Only one practice can bill Medicare for this service in a given month. And you can stop any time by telling us. It would end at the close of that month."

FQHC client practices. Omit the deductible language and disclose the 20 percent coinsurance only, per TW-CP-000 Section 7.4.

Documentation block. Record in the platform at the time of the call: date and time; method (verbal); who obtained consent; consenting party and, if a representative, name and relationship; billing practitioner; the patient's response; script version TW-CP-004 v1.0; QMB status at capture; the date of any consent the practice already documented, if known; and at initiation, the instrument administered and the score. The platform consent form captures these fields. Then enter the consent note in the practice EHR per TW-CP-000 Section 13.2.

8. Written consent

A written consent form, when used, contains every disclosure in Section 6 in substantially the script's language, plus signature and date, and the same documentation fields. The signed form is attached to the consent record as the source document.

9. Withdrawal

Per TW-CP-000 Section 9. Withdrawal is effective at the end of the calendar month in which it is received. Stopping BHI does not affect the patient's CCM, APCM, or RPM enrollment unless the patient says so. If the patient discloses thoughts of self-harm or a mental health crisis during a withdrawal call, staff follow the clinical escalation protocol before completing the administrative withdrawal.

10. Concurrency

99484 may be billed alongside CCM and RPM with time tracked separately. With an APCM base, BHI is billed as G0570 by the same practitioner in the same month, never as 99484. 99484 and CoCM codes are never billed in the same month for the same patient, which is moot under current scope. See TW-CP-000 Section 15.

11. FHIR binding

A G0570 claim candidate requires this consent and an active APCM consent (TW-CP-002) for the same patient and practitioner. See TW-CP-000 Section 18, rule 4.

Approval

Torch Wellness, LLC · BHI Consent Policy

TW-CP-004 · v1.0