Documenting integrated care: CoCM, general BHI and the minutes that make them billable

Integrated care has good evidence. A 2025 individual-participant meta-analysis in JAMA Psychiatry (Schillok et al.) pooled 35 studies and 20,046 adults. It found collaborative care produced better depression outcomes than usual care, with benefits lasting up to 12 months. The billing model is less familiar. CoCM and general BHI are monthly, time-based care management services, not visits. Practices that bill them like visits tend to lose the claim or fail the audit.

Two models, one rule between them#

Medicare pays for two kinds of behavioral health integration (BHI). Psychiatric Collaborative Care (CoCM) uses a defined team of three: a treating (billing) practitioner, a behavioral health care manager and a psychiatric consultant. General BHI covers other care models, and a single practitioner or clinical staff can deliver it. CMS's rule: you may not bill general BHI and CoCM codes for the same patient in the same month, though a patient can move between them over several months.

Treating (billing) practitioner

A physician or NPP whose scope includes E/M services. Directs the care manager, oversees treatment and stays involved through ongoing oversight.

Behavioral health care manager

Has formal education or specialized training in behavioral health, such as social work, nursing or psychology. Does not need to be licensed to bill psychotherapy. Maintains the registry, gives rating scales, delivers brief interventions and consults the psychiatric consultant. Administrative and clerical staff do not count.

Psychiatric consultant

A medical provider trained in psychiatry who can prescribe the full range of medications. Reviews the caseload, usually remotely, recommends changes and usually has no direct patient contact.

Before the first minute: initiating visit and consent#

Two things have to be in the chart before you bill any BHI code:

• An initiating visit with the billing practitioner: an AWV, IPPE, comprehensive E/M or TCM visit. For HCPCS G0323 (general BHI delivered by a clinical psychologist or clinical social worker), a psychiatric diagnostic evaluation (90791) serves as the initiating visit. The University of Washington AIMS Center notes that this visit is needed for new patients and for patients not seen in the year before integrated care starts.
• Consent. The patient agrees to the billing practitioner consulting specialists, including the psychiatric consultant, and is told that cost sharing applies to face-to-face and non-face-to-face services. CMS accepts verbal consent but requires that it be documented in the record. A new consent is needed only if the patient changes billing practitioners.

The codes and their time thresholds#

CMS says CPT time rules apply. Under the midpoint convention that most coding references and the AIMS Center use, 99492 can be reported at 36 minutes and 99493 at 31 minutes. The first 99494 unit requires at least 16 minutes beyond the base time (86 in month one, 76 later). Payers interpret this differently, so confirm with yours. G2214 covers months that fall short of the full threshold. CMS gives the example of a patient you see and then hospitalize or refer before the month's minutes add up.

What has to happen during the month#

For 99492, CMS lists the required elements: outreach and engagement, an initial assessment using validated rating scales with an individualized treatment plan, review by the psychiatric consultant, entering the patient in a registry and tracking progress there, participating in a weekly caseload consultation with the psychiatric consultant, and brief evidence-based interventions such as behavioral activation or motivational interviewing. Subsequent months (99493) add monitoring outcomes with validated scales and relapse-prevention planning as patients improve.

An episode of care ends when the patient reaches the treatment goals, when the team refers the patient for direct psychiatric care because goals aren't being met, or after six consecutive months without CoCM services.

New in 2026: add-ons for advanced primary care management#

The CY 2026 Physician Fee Schedule added three optional add-on codes for practices that bill advanced primary care management (APCM, base codes G0556–G0558) in the same month. G0568 and G0569 cover CoCM and G0570 covers general BHI. CMS says they are "meant to be directly comparable to existing CoCM and general BHI codes," but unlike the standard codes, they are not time-based. The same practitioner must bill the APCM base code that month. The existing CoCM and BHI codes remain for practices that don't bill APCM.

Tracking time that survives an audit#

Most CoCM audit findings involve time. Monthly totals typed into a note, with no record of what made them up, can't be verified. Record each activity when it happens, then total the month from those entries:

Common gaps#

• Consent obtained verbally but never recorded.
• No initiating visit in the past year for a returning patient.
• CoCM and 99484 billed for the same patient in the same month.
• Minutes from a separately billed therapy session counted toward CoCM.
• Weekly caseload reviews held but not documented per patient.
• Rating scales given but kept outside the registry, so the trend can't be shown.
• Medicaid or commercial claims billed on Medicare's rules without checking the payer's own policy. The AIMS Center notes that coverage of these codes is growing but still varies.

Federally qualified health centers and rural health clinics have their own CMS booklets and rules, including who can obtain consent. Read those rather than the physician fee schedule guidance.

Where Margent fits#

Margent does not run your CoCM registry. It supports the documentation around it. Outcomes gives and scores the validated scales CoCM requires and shows the trend in the note. Margent drafts care manager contacts with the date, activity and duration. Note checks, set up in your note rules, can check for consent on file, an initiating visit within your look-back period, and therapy time that shouldn't be counted twice, before a note is signed.