99605
Medication therapy management, new patient
Initial 15 minutes, face-to-face with the patient, provided by a pharmacist, for a patient new to the service.
CPT Codes
Comprehensive medication management billing codes: 99605, 99606 and 99607
These are the pharmacist medication therapy management codes. They are the billing route for comprehensive medication management, but the code titles describe the narrower service.
99606
Medication therapy management, established patient
Initial 15 minutes, face-to-face with the patient, provided by a pharmacist, for an established patient.
99607
Each additional 15 minutes
Reported with 99605 or 99606 for each further 15 minutes in the same encounter.
Name and Service
Why do the code titles say medication therapy management?
Because that is what the AMA descriptors say. These codes title medication therapy management services provided by a pharmacist, and they are the billing route most often used for comprehensive medication management.
The two are not the same service. Medication therapy management is a defined Medicare Part D program requirement with eligibility criteria set by the plan. Comprehensive medication management is a standard of clinical practice: a structured assessment of whether every medication a patient takes is appropriate, effective, safe and able to be taken as intended, continuing through follow-up until problems are resolved.
Stating this plainly matters more than it might appear. A reader who takes the code title as a description of the service will conclude the two are interchangeable, and they are not. The codes are the reimbursement mechanism; they do not define the clinical work.
Structure
How is the time counted?
In 15 minute increments within an encounter, rather than across a calendar month. This is a different structure from the care management codes, which accumulate time monthly.
99605 and 99606 differ only in whether the patient is new to the service or established. Both cover the initial 15 minutes. 99607 is the add-on for each further 15 minutes in the same encounter.
The descriptors describe a face-to-face service, so the reimbursement route constrains the delivery mode in a way the clinical service itself does not. A program delivering medication management remotely needs to establish how it will be reimbursed before it designs the workflow around it.
Pathways
Is medication management billed under Part D or Part B?
Both, through two different programs that are routinely treated as one. They sit in different parts of Medicare, select patients on different grounds, and are reported by different people.
01
Medication therapy management, Part D
A benefit every Part D plan must offer under 42 CFR 423.153(d). Eligibility is arithmetic: a plan may require up to three chronic diseases and up to eight Part D drugs, together with projected annual Part D drug costs at or above a threshold CMS sets. Enrollment is opt-out and targeting runs at least quarterly. The plan administers the program, and the completion rate for the annual comprehensive medication review is tracked as a Part D Star Ratings measure.
02
Chronic care management, Part B
A physician-office service reported on the chronic care management codes. A pharmacist can perform the medication work as clinical staff under the billing practitioner's general supervision, and the practitioner reports the code. Eligibility is a clinical judgment rather than a count: two or more chronic conditions expected to last at least twelve months or until death, placing the patient at significant risk.
03
Comprehensive medication management, neither
CMM is the standard for the clinical work itself, not a benefit and not a code. It can be delivered inside a Part D medication therapy management program, inside a Part B care management service, or under a Medicaid or commercial contract. That is why it has no code of its own.
The practical consequence is a billing one. CPT 99605, 99606 and 99607 are not payable under Medicare Part B, and pharmacists do not hold provider status under Part B. Medicare Advantage and Part D plans may pay for medication management, and state Medicaid programs and commercial payers use these codes, but a practice expecting Part B to reimburse a pharmacist directly on them has the wrong pathway.
The Part B route for pharmacist work is a different mechanism. The time counts as clinical staff time inside chronic care management, transitional care management or principal care management, and the billing practitioner reports it. The pharmacist performs the work; the practitioner reports the service and retains professional responsibility for it.
The two pathways also select different patients. A medication therapy management threshold is met by counting drugs and projected spend, so a patient with a genuinely difficult regimen who falls one drug short is not targeted, while a patient who clears the cost threshold on a single expensive product is. Care management eligibility turns on documented clinical risk instead. A program that needs to reach the patients who actually have medication problems, rather than the patients a threshold selects, should be clear about which of the two it is operating in.
Star Ratings measure sets are revised from year to year, and the medication review completion measure has moved in and out of the program. Confirm the measure set in force for the plan year rather than assuming it persists.
Common Questions
Related questions
Are 99605, 99606 and 99607 comprehensive medication management codes?
They are the codes most often used to bill it, but their AMA descriptors title medication therapy management services provided by a pharmacist. Comprehensive medication management is the broader clinical service. The code titles describe the narrower one.
What is the difference between 99605 and 99606?
Only whether the patient is new to the service or established. Both cover the initial 15 minutes of a face-to-face medication therapy management service provided by a pharmacist.
Does comprehensive medication management require a pharmacist?
In nearly every implementation, yes. The assessment of whether a regimen is appropriate, effective, safe and takeable rests on pharmacist clinical judgment. What the pharmacist may change without a new order depends on state law and on whether a collaborative practice agreement is in place.
Can the service be delivered remotely?
The clinical service can. The code descriptors describe a face-to-face service, so the reimbursement route is the constraint rather than the clinical work. Establish the billing pathway before designing a remote workflow around it.
Is medication therapy management the same as comprehensive medication management?
No. Medication therapy management is a Medicare Part D program requirement with plan-set eligibility criteria. Comprehensive medication management is a practice standard that continues through follow-up to resolution. They overlap in activity but differ in scope, trigger and endpoint.
What is the difference between medication therapy management and chronic care management?
They sit in different parts of Medicare. Medication therapy management is a Part D benefit every plan must offer, with eligibility set by counting chronic diseases, Part D drugs and projected drug spend against a threshold. Chronic care management is a Part B service reported by a physician practice, with eligibility resting on documented clinical risk. A pharmacist can perform medication work inside either, but only the second is reported by the practitioner on the care management codes.
Does Medicare Part B pay for CPT 99605, 99606 or 99607?
No. Those codes are not payable under Medicare Part B, and pharmacists do not hold provider status under Part B. Medicare Advantage and Part D plans may pay for medication management, and Medicaid programs and commercial payers use these codes, so the pathway depends on the payer rather than on the clinical service.
How can a practice be paid for pharmacist medication work under Medicare Part B?
As clinical staff time inside a care management service. A pharmacist's time can count toward chronic care management, transitional care management or principal care management under the billing practitioner's general supervision, with the practitioner reporting the code and retaining responsibility for the service. The pharmacist does not bill Medicare directly.
Code descriptors reflect the AMA CPT code set and the CMS HCPCS code set current as of CY2026. Both are revised annually, and Medicare Administrative Contractor and commercial payer policy varies. This page describes what each code covers and the conditions attached to reporting it. It is a reference, not billing advice for a specific claim, and it carries no payment rates.
Related reading
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