Workflow
TCM Contact Within 2 Business Days: CMS Rule and Examples
Count the deadline, distinguish contact from attempts, and give your care team a clear follow-up checklist.
Updated September 13, 2026. Educational workflow guidance; not a patient-specific billing determination.
In short
TCM calls for interactive contact with the patient or caregiver within two business days after discharge. If contact is unsuccessful, at least two separate, timely, documented attempts may support reporting when every other requirement is met. Continue outreach; do not automatically mark an unreached patient as either billable or ineligible.
Count business days, not 48 hours
Use weekdays excluding applicable holidays, not the hours your practice happens to be open. These examples assume no holidays except where noted. Confirm holiday handling with your billing team and payer guidance.
| Discharge | Business days after discharge | Contact deadline |
|---|---|---|
| Monday | Tuesday, Wednesday | Wednesday |
| Thursday | Friday, Monday | Monday |
| Friday | Monday, Tuesday | Tuesday |
| Friday, with a Monday holiday | Tuesday, Wednesday | Wednesday |
AAFP’s business-day explanation uses Monday through Friday except holidays, regardless of practice hours or when the discharge notification arrives.
An unsuccessful attempt is not a completed contact
CMS allows phone, email, or face-to-face contact by the practitioner or clinical staff working under their direction. The interaction must address patient status and needs beyond appointment scheduling. Staff must be permitted to perform the service under applicable law and practice policies.
For unsuccessful outreach, retain each attempt and continue trying to make contact. The exception does not remove the other service requirements or make late attempts timely. Have a billing reviewer assess an incomplete record rather than backdating or relabelling the activity.
For example, keep Tuesday’s unanswered call and Wednesday’s unanswered call as two separate entries after a Monday discharge. Set a follow-up task and verify the remaining requirements. Do not change either entry to “patient contacted” just because a later visit is booked.
Track the visit deadline separately
For 99495, the visit is due within 14 calendar days with at least moderate medical decision-making; 99496 requires a visit within 7 calendar days and high complexity. Medication reconciliation is due no later than that visit. A timely call alone does not make the episode billable. See CMS’s face-to-face requirements.
A practical contact-attempt documentation checklist
Use this suggested operational checklist to prepare a record for review, not as a substitute for the full CMS requirements or your approved clinical documentation template.
- Discharge and deadlines: Record the discharge date, source of notification, calculated contact deadline, and separate visit deadline. Flag a late discharge notification for staff review.
- Each separate attempt: Log the date, time, method, staff member, intended recipient, and outcome. Distinguish no answer, voicemail, wrong number, and completed interaction; do not overwrite earlier attempts.
- Completed interaction: Identify whether the patient or caregiver responded, who performed the interaction, the needs discussed, and the clinical follow-up requested. Keep the record in the practice’s approved clinical system.
- Next action and ownership: Assign a named owner and next action after an unsuccessful attempt or concerning response. Keep the task open until the team resolves it; a scheduled call is not a completed contact.
- Billing review: Make the attempt history, visit record, medication reconciliation, and other supporting documentation available to the billing reviewer. Do not automatically convert a call status into a billable claim.
Where automation fits—and where staff retain responsibility
Evaluate Positive Check as support for outreach, structured responses, and staff handoffs. Do not assume that an AI-only call independently satisfies a clinical contact requirement. Agree who reviews unsuccessful attempts, handles concerning responses, and makes billing decisions before running a pilot.
Use the implementation guide to plan ownership and exception testing. For ongoing chronic care after discharge, review TCM and CCM in the same month and the 2026 CCM billing guide.
Common questions
If a patient is discharged on Friday, when is TCM contact due?
The usual deadline is Tuesday, unless a holiday changes the business-day count. Monday and Tuesday are the two business days after Friday. Plan coverage before the weekend, rather than waiting for the discharge list to be reviewed on Monday. A late notification does not restart the discharge-based clock.
Can TCM still be reported if the patient cannot be reached?
Sometimes. CMS permits reporting after at least two separate, timely, documented unsuccessful attempts if all other TCM requirements are met, including the timely face-to-face visit. Continue trying to reach the patient. A record with no timely attempts is different from a record showing unsuccessful outreach; send ambiguous cases to the billing reviewer.
Does leaving a voicemail complete the TCM contact requirement?
A voicemail is an attempt, not a completed interactive contact. Label it that way in the record and assign the next attempt. Keep an unanswered message separate from a conversation about the patient’s status and needs. The documented-attempt exception may apply, but a voicemail alone is not a billing determination.
Does an AI call independently qualify as the required clinical contact?
Do not assume that it does. CMS describes contact by the practitioner or permitted clinical staff; an automated call log alone does not establish that requirement. Use automation to support outreach and handoffs, and have the practice validate who performs the qualifying interaction, what is documented, and who reviews exceptions before billing.
What should a practice test before automating post-discharge outreach?
Test a Friday discharge, a holiday, an unanswered call, an incorrect phone number, and a response needing clinical follow-up. For each scenario, check the deadline, attempt history, named staff owner, and next action. Use synthetic patient records during testing and agree how the team will handle failures before expanding the workflow.
How should TCM outreach connect with ongoing CCM work?
Keep the discharge follow-up record and the monthly CCM activity record distinguishable, even when the same team manages both. Assign each activity to the service it supports and never count the same work twice. Review eligibility and documentation separately; completing an outreach call does not by itself establish either program’s billing requirements.
Source check: CMS MLN908628 (August 2025) and AAFP’s TCM guidance, accessed September 13, 2026. Have a qualified billing reviewer validate your workflow against current CMS, CPT, MAC, and payer requirements. This page does not assert clinical reviewer approval.