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Behavioural Health Integration (BHI): Billing Mental Health Care Management Under Medicare



Behavioural Health Integration (BHI) is a Medicare service category that reimburses providers for non-face-to-face care management of patients with mental, behavioural health, or psychiatric conditions. BHI recognizes that mental health conditions frequently coexist with physical chronic diseases, and that primary care practices are often the first and most consistent point of contact for patients whose behavioral health needs go unaddressed.


CMS recognizes two distinct BHI models:

General BHI (CPT 99484):

CPT 99484 covers at least 20 minutes of clinical staff time per calendar month, directed by a physician or QHP, for care management services related to behavioral health conditions. The required service elements include initial assessment or follow-up monitoring using applicable validated rating scales (such as the PHQ-9 for depression or the GAD-7 for anxiety), behavioral health care planning, facilitating and coordinating treatment (psychotherapy, pharmacotherapy, counseling, or psychiatric consultation), and maintaining continuity of care with a designated member of the care team.

CPT 99484 may only be billed once per patient per month, regardless of how much time is spent beyond the 20-minute minimum. It is a single-unit code with no add-on structure.

Clinical staff providing services under 99484 are not required to have additional education or training in behavioral health beyond what their licensure and scope of practice require.

Psychiatric Collaborative Care Model (CoCM):

CoCM uses three CPT codes: 99492 (initial month, first 70 minutes), 99493 (subsequent months, first 60 minutes), and 99494 (add-on for each additional 30 minutes). CoCM requires a dedicated behavioural health care manager with formal education or specialized training in behavioural health, plus consultation with a psychiatric consultant. This model is more resource-intensive than general BHI and is less commonly implemented in standard care management programs.

BHI and CoCM cannot be billed in the same month for the same patient. However, BHI or CoCM can be billed in the same month as CCM or TCM, provided that time and activities are tracked separately.

Eligible Conditions:

Any mental, behavioural health, or psychiatric condition treated by the billing practitioner qualifies, including depression, anxiety disorders, substance use disorders, post-traumatic stress disorder (PTSD), bipolar disorder, and attention deficit disorders. The diagnosis may be pre-existing or newly identified by the billing practitioner.

 

Integration with APCM:

In the CY 2026 Physician Fee Schedule proposed rule, CMS introduced three optional add-on G-codes (GPCM1, GPCM2, GPCM3) that allow APCM-billing providers to layer BHI and CoCM services on top of the APCM base codes. These add-on codes mirror the existing BHI and CoCM code values while removing time-based documentation requirements, supporting a more holistic, team-based care approach. CMS also proposed removing time-based documentation requirements for the existing BHI and CoCM codes when billed alongside APCM.

 

 

 

Sources:

CMS Medicare Learning Network, "Behavioral Health Integration Services"; AAFP coding guidance for BHI;

Rural Health Information Hub (RHIhub) BHI overview, updated February 2026;

DLA Piper analysis of CY 2026 MPFS Proposed Rule.

 

 



 

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