CMS APCM Behavioral Health Add-On G-Codes

A source-verified guide to G0568, G0569, and G0570

Effective date: January 1, 2026
Source review current through: August 12, 2026
Scope: Original Medicare fee-for-service under the Medicare Physician Fee Schedule
Primary authorities: CY 2026 Physician Fee Schedule final rule, current CMS HCPCS and RVU files, and current CMS APCM and Behavioral Health Integration guidance

This guide explains federal Medicare requirements. It is not legal advice, a guarantee of payment, or a substitute for a Medicare Administrative Contractor (MAC), payer, coding, clinical, or state-law review. Medicare Advantage and other payers may adopt different coverage, edits, documentation rules, or effective dates.

The short version

Beginning January 1, 2026, CMS permits a practitioner to report one of three optional behavioral-health add-ons in a month in which that same practitioner reports an APCM base code:

The most important rules are:

1. They are add-ons, not standalone codes. The same practitioner must report G0556, G0557, or G0558 in the same calendar month.
2. They are not time-based. Do not import the 20-, 60-, or 70-minute thresholds from the standalone codes.
3. They are still service-based. CMS rejected the idea that a practice could bill merely because it has behavioral-health capabilities. The patient-specific elements of the selected code must actually be furnished and documented in the medical record in each billed month.
4. Only one behavioral-health model applies in a month. Do not report General BHI and CoCM together for the same patient in the same month. Do not report both the initial and subsequent CoCM add-ons in one month.
5. A diagnosis is not enough. A problem-list condition can identify a candidate, but it does not establish that the month's required services occurred.
6. No monthly office visit is required. After any required initiating visit, certain monthly components may be performed remotely when clinically appropriate.

These points come directly from the CY 2026 PFS final rule, 90 FR 49469–49471, the January 2026 CMS BHI booklet, and the July 2026 CMS Alpha-Numeric HCPCS file.

How to read this guide

This guide deliberately separates four kinds of statements:

• CMS requirement — expressly stated in a code descriptor, final rule, or CMS guidance.
• Conditional requirement — required only when the condition named by CMS occurs, such as revising a plan when the patient is not progressing.
• Recommended record practice — a practical way to make the federal requirement auditable; it is not a CMS-mandated form or field.
• Unresolved CMS question — an issue the reviewed federal sources do not answer clearly. These questions should go to the applicable MAC or payer rather than being filled with invented rules.

1. What CMS changed in 2026

Before 2026, practices commonly used the time-based General BHI and CoCM codes 99484, 99492, 99493, and 99494. APCM, introduced for 2025, uses a different monthly model and does not depend on counting staff minutes. CMS concluded that requiring time tracking for behavioral-health integration while APCM itself did not require it created an avoidable mismatch.

For 2026, CMS created:

• G0568, directly comparable to the initial CoCM service 99492;
• G0569, directly comparable to the subsequent CoCM service 99493; and
• G0570, directly comparable to General BHI service 99484.

CMS removed the minute thresholds only when these new G-codes are used as APCM add-ons. CMS did not remove the underlying clinical service elements. It also did not create an APCM version of 99494, because 99494 exists only to report additional CoCM time. See 90 FR 49469–49471 and the CMS final-rule summary, p. 4.

The key policy distinction

APCM contains important practice-level capabilities that must be continuously available. These behavioral-health add-ons are different. In the final rule, a commenter suggested allowing practices to attest that they were capable of integrated behavioral-health care without documenting each service element. CMS declined. CMS explained that the care delivered and the elements of the particular add-on must be documented in the medical record. See 90 FR 49470.

Therefore:

No minute threshold does not mean no monthly work.

An evergreen care plan, a diagnosis, a configured care team, access to a psychiatrist, or a billing attestation is not enough by itself.

2. Shared requirements for all three add-ons

The requirements in this section apply before the code-specific elements described later.

2.1 APCM base-code dependency

G0568, G0569, and G0570 are optional add-on codes. For any month in which one is reported:

• the practitioner must also report one APCM base code: G0556, G0557, or G0558;
• the base and add-on must be reported by the same practitioner; and
• the base and add-on must be for the same calendar month.

The federal rule says same practitioner and same month. It does not say that the two codes must have the same date of service or appear on the same claim. Using one claim with two lines is operationally simple and may reduce payer confusion, but it is a workflow choice unless a payer or MAC directs otherwise. See 90 FR 49469–49471.

For conservative operations, “same practitioner” should be treated as the same billing practitioner/NPI, not merely another clinician in the same group or TIN.

2.2 The practitioner must qualify for APCM and BHI

CMS's BHI materials describe physicians and nonphysician practitioners whose scope includes evaluation and management services, including physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse-midwives. CMS permits physicians and eligible nonphysician practitioners to report APCM when they meet the APCM responsibility, focal-point, enrollment, and scope requirements; CMS's linked Advanced Practice NPP guidance includes certified nurse-midwives. The APCM billing practitioner must also be responsible for the patient's primary care and serve as the continuing focal point for the patient's needed health care. A psychiatric consultant, behavioral-health care manager, therapist, or another practitioner cannot independently report the add-on without also being the practitioner who reports the APCM base. See the CMS BHI booklet, pp. 3–4 and the CMS APCM service page.

2.3 A qualifying behavioral-health condition

The patient must have an identified or presenting mental, behavioral, or psychiatric condition that, in the billing practitioner's clinical judgment, warrants behavioral-health assessment, care planning, and intervention. Substance use disorder may qualify. The condition may already be diagnosed or may be refined during care. It must be treated through BHI by the billing practitioner and qualifying team; a diagnosis managed wholly elsewhere, with no BHI treatment by this practitioner or team, does not establish the requirement. See the CMS BHI booklet, p. 3 and CMS BHI FAQ, p. 2.

CMS does not publish:

• a diagnosis allowlist;
• a requirement that every qualifying condition use an F-chapter ICD-10-CM code;
• a restriction to depression or anxiety; or
• a requirement that the patient have another chronic medical condition for BHI itself.

The APCM base code's own eligibility and tier rules still apply. A problem-list or claim diagnosis is useful for candidate discovery, but clinical judgment and the actual monthly service determine add-on eligibility.

2.4 Consent

The BHI and APCM consent requirements overlap, but they are not identical.

BHI consent

Before BHI begins, the record must show that the patient:

• gave the billing practitioner permission to consult relevant specialists, including a psychiatric consultant; and
• was told that Medicare Part B cost sharing applies to both face-to-face and non-face-to-face BHI services, even when supplemental coverage may pay the patient's share.

Verbal consent is permitted, but it must be documented in the medical record. CMS says a new BHI consent is needed if the billing practitioner changes. See the CMS BHI booklet, p. 4 and CMS BHI FAQ, pp. 4–5.

APCM consent

Before APCM begins, the patient must be informed about:

• the availability of the service;
• the practitioner's intent to assume responsibility for the patient's primary care and serve as the continuing focal point for needed health care;
• the ongoing monthly nature of APCM;
• the rule that only one practitioner may furnish and be paid for APCM in a calendar month;
• the patient's right to stop the service, effective at the end of the calendar month;
• the fact that consent does not restrict access to other Medicare-covered care; and
• applicable cost sharing.

APCM consent may also be verbal or written and must be documented. CMS describes it as a one-time consent before starting, subject to a practitioner change and the patient's right to stop. See the CMS APCM service page.

May the consents be combined?

CMS does not require two paper forms, and the reviewed sources do not expressly approve or prohibit one combined form. A single conversation or record can reasonably capture both complete sets of disclosures, but that is an implementation interpretation—not an express CMS statement.

The defensible approach is to make the two scopes clear in one workflow:

• record affirmative APCM consent;
• record affirmative BHI consent and specialist-consultation permission;
• document the distinct cost-sharing disclosures; and
• preserve the ability to revoke one service without falsely recording revocation of the other.

A legacy APCM consent that never addressed BHI specialist consultation and BHI cost sharing should not be assumed to cover BHI. Obtain and document the missing BHI consent elements before starting BHI.

Medicare billing consent does not replace any authorization required by HIPAA, state law, or federal substance-use-disorder privacy rules.

2.5 Initiating visit

CMS's BHI guidance requires an initiating visit for a new patient or a patient not seen within the year before BHI begins. The billing practitioner must perform the initiating visit and introduce and discuss BHI during a qualifying face-to-face service, which may be:

• a comprehensive new- or established-patient E/M visit (99202–99205 or 99212–99215);
• an Annual Wellness Visit;
• an Initial Preventive Physical Examination; or
• a qualifying face-to-face Transitional Care Management visit.

The initiating service is separately payable, may occur in the preceding calendar month, and does not qualify merely because an eligible visit happened—the BHI discussion must occur. See the CMS BHI FAQ, pp. 4–5 and CMS BHI booklet, p. 3.

An unresolved APCM/BHI interaction

APCM uses a different initiating-visit test. It generally requires a separately paid visit for a new patient. The APCM visit is not required when the billing practitioner or another physician, qualified health care professional, or practitioner in the same group practice furnished professional services to the patient within the prior three years, or when that practice furnished APCM, CCM, or PCM to the patient within the prior year. CMS's January 2026 BHI booklet says an APCM add-on user must meet all applicable requirements, but CMS has not expressly reconciled BHI's one-year test with APCM's three-year practice test.

The safest reading is to evaluate both tests independently. For example, a patient seen by the practice 14 months ago may satisfy the APCM test but still trigger the BHI initiating-visit requirement. One visit can plausibly satisfy both when it meets both sets of rules and BHI is actually discussed, but CMS has not published an add-on-specific statement confirming that interaction.

CMS's reviewed BHI sources describe the initiating visit as face-to-face but do not clearly resolve whether a video Medicare telehealth visit qualifies for this step. Do not assume an audio-only call qualifies; ask the applicable MAC for virtual-initiation guidance.

CMS-source precision: CMS's current APCM web page and the controlling CY 2025 final rule use the same-practice and prior-care-management exceptions described above. A short CMS APCM FAQ uses narrower “billing practitioner” wording for the three-year lookback. Where those summaries differ, organizations should follow the final rule/current main guidance and confirm any disputed fact pattern with the MAC.

2.6 Monthly E/M and location of service

CMS does not require an E/M visit every billed BHI month. After any required initiating visit, certain BHI components may be furnished remotely by telephone, audio/video, or another clinically appropriate method. CMS treats these as care-management services, not Medicare telehealth services under Social Security Act § 1834(m). General BHI clinical staff do not have to furnish or be available for face-to-face services. A CoCM behavioral-health care manager must be available to furnish in-person services, although no actual in-person encounter is required each month; the psychiatric consultant commonly works remotely. See the CMS BHI FAQ, pp. 3–6.

When work is remote, CMS generally instructs practitioners to report the place of service where they would ordinarily furnish face-to-face care—not automatically the patient's home. A patient may also receive BHI while spending part or all of the month in a facility or institution. State scope-of-practice, licensure, supervision, and payer rules still apply.

2.7 Auxiliary personnel and general supervision

CMS designated the new codes as care-management services. Qualifying auxiliary personnel may furnish portions incident to the billing practitioner under general supervision. General supervision means the practitioner provides overall direction and control but need not be physically present while the service occurs. See 90 FR 49469 and the CMS BHI booklet, pp. 3–4 and 11–12.

This flexibility does not erase the code's care-team requirements. Auxiliary personnel furnishing incident-to BHI must be employees of or working under contract to the practitioner Medicare pays; general supervision alone does not create that relationship. State licensure and scope-of-practice rules also apply. The billing practitioner remains responsible for direction, oversight, collaboration, reassessment, and treatment management.

For every BHI model, the billing practitioner must personally perform aspects of the service. The entire clinical service cannot be outsourced while the practitioner provides only nominal supervision. CMS does not specify a minimum amount of personal practitioner time for these untimed add-ons. See the CMS BHI FAQ, p. 3.

3. G0570 — General Behavioral Health Integration

3.1 What G0570 represents

G0570 is the APCM add-on for a qualifying month of General BHI. It is not CoCM. It is the least operationally complex of the three codes because it does not require a formal psychiatric consultant, a designated behavioral-health care manager, a registry, or weekly psychiatric caseload review.

The billing practitioner may furnish all of General BHI directly or may use qualified clinical staff. When staff participate, CMS expects a continuous relationship between the patient and a designated care-team member and an integrated relationship between that team member and the rest of the care team. Clerical or administrative work is not clinical BHI. See the CMS BHI booklet, pp. 9 and 11–12.

3.2 Every billed G0570 month must contain all four elements

G0570 is directed by a physician or other qualified health care professional. The current CMS descriptor and 90 FR 49470 establish four clinical elements in addition to that direction and the shared add-on prerequisites.

Element 1 — Initial assessment or follow-up monitoring

The month must include either:

• an initial behavioral-health assessment; or
• follow-up monitoring of the patient's behavioral or psychiatric status.

The element includes the use of applicable validated rating scales. CMS does not mandate one particular instrument or state that PHQ-9 must be used for every patient. The selected measure should be clinically appropriate to the condition and purpose.

Recommended record evidence: condition being monitored; assessment date; findings; scale name, administration date, score, and clinical interpretation or trend. The descriptor says “applicable” validated scales, but CMS supplies no add-on-specific example or safe harbor for a month in which the team believes no scale applies. Treat billing without a validated scale as an unresolved CMS/MAC question; documenting the clinical basis is prudent but is not an established substitute for scale use.

Element 2 — Behavioral-health care planning

The month must include behavioral-health care planning related to the patient's behavioral or psychiatric problem. The plan must be revised when the patient is not progressing or the patient's status changes.

The revision clause is conditional. CMS does not require an artificial plan change every month for a stable patient. But a static plan existing somewhere in the chart, with no patient-specific planning activity during the billed month, does not by itself prove this element.

Recommended record evidence: problem and goals addressed; current treatment strategy; progress against goals; clinically meaningful plan review or planning action; changes made when indicated; and why the plan remained appropriate if no change was needed.

Element 3 — Facilitation and coordination of treatment

The month must include actual facilitation and coordination of behavioral-health treatment. One integrated patient-specific activity may evidence both functions, but the record should not treat either facilitation or coordination alone as the entire element. The descriptor gives examples:

• psychotherapy;
• pharmacotherapy;
• counseling; and/or
• psychiatric consultation.

The examples are alternatives, not a requirement to provide every modality. The activity must be patient-specific and clinical. Merely having a referral list, psychiatrist contract, or treatment option available does not satisfy the element.

Recommended record evidence: what action occurred; the treatment or provider involved; date; who participated; result; barriers addressed; and next step. Examples include coordinating a psychotherapy referral and closing the loop, managing a behavioral-health medication plan, communicating clinically relevant information with a treating therapist, arranging counseling, or obtaining and acting on psychiatric input.

Element 4 — Continuity with a designated care-team member

The month must preserve continuity of care with a designated member of the care team. General supervision alone does not establish this relationship.

CMS does not prescribe a fixed number of contacts. The record should nevertheless make clear who the designated team member is and how patient-specific continuity was furnished during the month.

Recommended record evidence: designated team member's name or role; the continuity or follow-up activity; date; patient or team communication as applicable; and planned follow-up.

3.3 The minimum defensible G0570 month

Assuming the shared APCM, condition, consent, practitioner, and initiating-visit requirements are already met, the minimum billable month is not a number of minutes or contacts. It is a complete four-element service:

• assessment or follow-up monitoring occurred;
• an applicable validated scale was used; if the team believes none applies, billing without one has been resolved with the MAC;
• behavioral-health care planning occurred;
• the plan was revised if progress or status required it;
• actual treatment facilitation and coordination occurred; and
• continuity with a designated care-team member occurred.

All of that work must be patient-specific and documented in the medical record for the calendar month. The same practitioner must also report the patient's APCM base code that month.

3.4 What does not satisfy G0570 by itself

• A depression, anxiety, dementia, or SUD diagnosis on the problem list.
• A screening score with no care planning, treatment action, or continuity.
• An evergreen care plan that no one actively used during the month.
• A referral placed in a prior month with no qualifying current-month facilitation and coordination.
• Access to a therapist or psychiatrist.
• Medication appearing on the medication list with no current-month BHI activity.
• Consent alone.
• Billing or claim preparation.
• A generic checkbox stating that all requirements were available.

3.5 A compliant stable-patient example

A patient with anxiety is already enrolled in APCM and General BHI. In the month, the designated nurse follows up, administers an appropriate validated scale, records improvement, reviews the behavioral-health goals and current plan with the patient, confirms no plan revision is clinically needed, coordinates a medication question with the billing practitioner, communicates the resulting instruction to the patient, and documents the next follow-up. No office visit occurs and the team spends fewer than 20 minutes.

If the shared prerequisites and medical necessity are met, this can support G0570: all four elements occurred, and there is no minute threshold. Stability means a plan revision was not required; it does not eliminate the need for monitoring, planning, treatment facilitation and coordination, and continuity.

4. G0568 — Initial Psychiatric Collaborative Care Model month

4.1 What G0568 represents

G0568 is the initial-month APCM add-on for the Psychiatric Collaborative Care Model. CoCM is a defined team model, not a synonym for any primary-care collaboration with a mental-health clinician.

CoCM requires three distinct roles:

1. Treating/billing practitioner — directs the service and reports both APCM and the add-on.
2. Behavioral-health care manager — maintains a continuous patient relationship, performs care-management and brief-intervention work, maintains the registry, and participates in psychiatric consultation.
3. Psychiatric consultant — reviews the caseload and patient status and recommends diagnostic or treatment adjustments.

One person cannot perform all three CoCM roles. See the CMS BHI booklet, pp. 5 and 11–12 and CMS BHI FAQ, pp. 1–4.

4.2 Team qualifications and relationships

CMS describes the behavioral-health care manager as having formal education or specialized behavioral-health training; CMS does not specify a minimum degree. The manager must have an integrated relationship with the care team, maintain a continuous relationship with the patient, be able to engage outside ordinary clinic hours when needed, maintain the registry, and be available to provide in-person services even though an in-person encounter is not required each month.

The psychiatric consultant is a medical professional trained in psychiatry and qualified to prescribe the full range of medications. The consultant commonly works remotely and ordinarily does not directly see or prescribe for the patient. For substance-use-disorder care, CMS permits an appropriately qualified addiction-medicine professional to fill the consultant role. Team members may be contracted, subject to Medicare and state requirements. CMS says the psychiatric consultant need not participate in Medicare because Medicare pays the billing practitioner for the bundled service. See the CMS BHI booklet, pp. 5 and 11–12 and CMS BHI FAQ, pp. 1–2 and 5–6.

4.3 Every billed G0568 month must contain all initial elements

The month consists of behavioral-health care-manager activities performed in consultation with a psychiatric consultant and directed by the treating physician or other qualified health care professional. The current CMS HCPCS descriptor and 90 FR 49469 require:

1. Outreach and engagement in treatment. The patient must actually be engaged; unsuccessful outreach alone does not demonstrate the complete descriptor.
2. Initial assessment with validated rating scale(s). The record should connect the instrument and findings to the presenting condition.
3. An individualized treatment plan. The plan should identify the problem, goals, interventions, follow-up approach, and responsible participants.
4. Psychiatric-consultant review. The consultant reviews the patient and individualized treatment plan. If the psychiatric consultant recommends modifications, the plan must be modified accordingly to satisfy the descriptor. A treating practitioner who declines a recommendation should document the clinical reasoning, but the reviewed CMS sources do not make that documentation an alternative to the descriptor.
5. Registry entry and tracking. The patient is entered into a registry and follow-up and progress are tracked with appropriate documentation.
6. Participation in weekly caseload consultation. The care manager participates in the weekly psychiatric-consultant caseload-review process.
7. Provision of brief interventions using evidence-based techniques. Actual patient-specific intervention activity must occur in the billed month. CMS names behavioral activation, motivational interviewing, and other focused strategies as examples but does not prescribe a numerical count in the add-on descriptor.

There is no 70-minute requirement for G0568. There is also no reduced clinical bundle because the month started late. A month supports G0568 only if the required initial elements were actually completed and documented.

4.4 What “weekly caseload consultation” does and does not mean

CMS requires participation in weekly caseload consultation and describes regular weekly caseload reviews that include patient treatment plans and status. It does not require a weekly direct psychiatrist-patient encounter, prescribe a note count, or name a specific registry platform. The reviewed sources do not state a minimum number of patient-specific discussions per month or expressly say whether every patient must be discussed at every weekly meeting; practices should not invent either a universal encounter rule or a permissive minimum.

The record should show that the required weekly process operated and should preserve the patient-specific consultant review, recommendations, and clinical response that support the billed service. A psychiatrist's name on a staffing list is not enough.

4.5 Recommended G0568 record checklist

This is an audit-oriented implementation checklist, not a CMS form:

• behavioral-health condition and clinical reason for CoCM;
• treating/billing practitioner;
• behavioral-health care manager and qualifications/role;
• psychiatric consultant and role;
• outreach date(s), engagement result, and treatment start;
• initial assessment findings;
• validated scale name, date, baseline score, and interpretation;
• individualized treatment goals and plan;
• consultant review date, recommendations, and disposition;
• plan modifications when recommended;
• registry enrollment and baseline/tracking fields;
• evidence of the weekly caseload-consultation process;
• brief intervention technique, date, focus, and patient response; and
• follow-up plan.

4.6 What does not satisfy G0568 by itself

• Assigning a care manager and psychiatric consultant.
• Adding the patient to a registry without assessment and treatment.
• Screening and creating a care plan without consultant review, weekly consultation, and brief intervention.
• Unsuccessful outreach with no engagement.
• A psychiatrist reviewing the chart without the other CoCM elements.
• General BHI work that does not use the full CoCM model.
• Reaching 70 minutes while omitting a required element.

5. G0569 — Subsequent Psychiatric CoCM month

5.1 What G0569 represents

G0569 describes a qualifying subsequent calendar month in an active CoCM episode. It is not a passive maintenance code. The patient remains in the registry and the team continues measurement-based, consultant-supported treatment.

The subsequent-month behavioral-health care-manager activities remain in consultation with a psychiatric consultant and under the direction of the treating physician or other qualified health care professional. There is no 60-minute threshold for G0569, but every listed required element must be furnished and documented. Within those elements, treatment changes are required only as indicated, and relapse-prevention planning applies as the patient approaches remission, goals, and discharge. See 90 FR 49469–49470.

5.2 Required subsequent-month elements

1. Registry follow-up and progress tracking. The patient's status, follow-up, and progress are updated in the registry with appropriate documentation.
2. Weekly psychiatric caseload consultation. The care manager continues participating in the weekly consultant-review process.
3. Ongoing collaboration and coordination. The team maintains ongoing collaboration with, and coordinates the patient's mental-health care with, the treating physician or other qualified health care professional and any other treating mental-health providers involved in the patient's care.
4. Progress review and treatment recommendations. The team conducts the additional progress review and documents recommendations for treatment changes when indicated, including medication-related recommendations based on psychiatric-consultant input.
5. Provision of brief interventions using evidence-based techniques. Actual patient-specific intervention activity must occur in the billed month. CMS names examples but does not prescribe a numerical count in the add-on descriptor.
6. Validated outcome monitoring. Patient outcomes are monitored using validated rating scales.
7. Relapse-prevention planning as the patient reaches that stage. This applies as the patient achieves remission or other treatment goals and prepares for discharge from active treatment.

5.3 Conditional elements are not automatic monthly actions

The descriptor does not require:

• a medication change every month;
• a plan change when no change is clinically indicated;
• coordination with a nonexistent outside mental-health provider; or
• relapse-prevention planning for a patient who is not yet approaching remission, goals, or discharge.

It does require the underlying review, collaboration, monitoring, and intervention. When a conditional action is not applicable, a brief patient-specific rationale makes the record easier to audit, but CMS does not prescribe a special “not applicable” field.

5.4 Recommended G0569 record checklist

• active episode and prior initial CoCM work;
• registry update with progress and follow-up;
• weekly caseload-consultation process evidence;
• patient-specific consultant review and recommendations, as applicable;
• collaboration and coordination with the treating/billing practitioner;
• coordination with any other treating mental-health providers involved in the patient's care;
• treatment recommendation and treating-practitioner disposition;
• brief intervention technique, date, focus, and patient response;
• validated scale name, date, score, interpretation, and trend;
• relapse-prevention planning when the patient is at that stage; and
• next follow-up and treatment plan.

5.5 Does G0569 require a previously paid G0568 claim?

CMS calls G0569 a subsequent CoCM month. The reviewed federal sources do not say that a previously submitted or paid G0568 or 99492 claim is a condition of payment. The record should establish a prior first activity month in which every required initial element was furnished and that the current month is truly subsequent.

Therefore, a prior G0568 claim is useful evidence but should not be converted into an invented federal prerequisite. For example, if the first care-manager activity month contained every G0568 element but was not billed, the next qualifying CoCM month may still fit the G0569 descriptor. Because CMS has not published an add-on-specific sequencing example, confirm unusual histories with the MAC.

6. General BHI versus CoCM

CMS says General BHI and CoCM may not both be reported for the same patient in the same calendar month, although the patient's care model may change across months. See the CMS BHI booklet, p. 9 and CMS BHI FAQ, p. 1.

Choosing the model

Use the care actually delivered—not payment, diagnosis, or staffing availability—to select the model:

• If all General BHI elements occurred without the formal CoCM structure, G0570 may apply.
• If all initial CoCM elements occurred in a properly staffed episode, G0568 may apply.
• If all subsequent CoCM elements occurred in that episode, G0569 may apply.
• If no model's complete elements occurred, report no behavioral-health add-on.

A practice should not label an informal therapist referral plus occasional psychiatrist access as CoCM. Conversely, a fully functioning CoCM team should not report both a CoCM add-on and G0570 for the same patient and month.

7. CoCM episodes and transitions

CMS's January 2026 booklet describes a CoCM episode as ending when:

• treatment goals are met;
• treatment goals are not met and the patient is referred to direct psychiatric care; or
• no CoCM service occurs for six consecutive calendar months.

See the CMS BHI booklet, p. 5.

Clear cases

• G0568 describes the first calendar month of behavioral-health care-manager activities in the episode, provided every required initial element is furnished.
• An incomplete first activity month supports no G0568 claim. CMS has not explained whether a later month that completes or repeats the initial work may be treated as the “first” month for G0568; confirm that sequencing with the MAC.
• G0569 describes a qualifying subsequent calendar month in an active episode.
• A subsequent month with incomplete CoCM service supports no G0569, even if the episode remains open.
• Switching from General BHI to newly initiated CoCM points to G0568 only when that first activity month contains all initial elements.
• Switching from CoCM to General BHI in a later month may support G0570 if all General BHI elements occur.

Questions CMS has not expressly resolved for the new add-ons

CMS does not provide detailed G-code examples for gaps and restarts. The most natural episode-based interpretations are:

• after a gap of one to five months, a resumed qualifying month in the same episode is subsequent (G0569); and
• after six consecutive months with no CoCM, the prior episode has ended, so a genuinely restarted episode would ordinarily begin with G0568 and repeat the required initial work.

Those are reasoned interpretations, not explicit add-on instructions. Confirm atypical restart cases with the MAC. A new diagnosis label or a new calendar year alone does not automatically create a new episode.

8. What must be documented in the medical record

8.1 CMS's actual documentation rule

CMS does not prescribe a special note title, a separate behavioral-health care-plan module, a particular EHR, or one monthly PDF. It does require the medical record to show that the patient-specific care was delivered and that the elements of the particular add-on were furnished. See 90 FR 49470.

Evidence may be distributed across appropriate chart locations—for example, an assessment, rating-scale result, care plan, care-management note, consultant recommendation, registry record, and coordination note—provided the record is complete and auditable for the billed month.

8.2 Does a practice need a separate care-plan module?

No federal source reviewed requires a separately titled BHI care plan or a second care-plan application. An existing comprehensive APCM care plan can support the requirement if it contains the necessary behavioral-health content and the monthly record shows the required planning activity.

For General BHI, the plan should address the behavioral or psychiatric problem, goals, treatment strategy, responsible participants, monitoring, progress, and revisions when progress or status requires them. For CoCM, the initial individualized treatment plan must also undergo psychiatric-consultant review, with modifications made if recommended.

The distinction is about content and work, not document count.

8.3 Is a monthly EHR write-back required?

CMS does not name Athena, require a “write-back,” or mandate one monthly summary note. The answer depends on where the official supporting record already exists:

• If all required current-month services and elements are already documented in the medical record: no duplicative note is federally required merely to bill.
• If qualifying work occurred in another care-management system and that system's records are maintained as part of the accessible medical record: a separate EHR summary is not expressly mandated, though the organization should ensure the documentation can be produced and tied to the claim.
• If the EHR contains none of the required evidence and the external documentation is not part of the retrievable medical record: the record is not ready to support the add-on. A dated summary or other reliable incorporation into the medical record is a sensible remediation before billing.
• If nothing happened except billing: do not create a note that implies care occurred. There is no qualifying add-on service to report.

The practical goal is not “one note every month.” It is a reliable, retrievable medical record that proves every required element for the billed month.

8.4 Recommended documentation standard

For each element, a strong record answers:

This is a recommended audit structure, not a CMS-required template.

8.5 Suggested G0570 monthly summary structure

If an organization uses one monthly summary, it could include:

1. behavioral-health condition and current clinical status;
2. assessment or monitoring findings;
3. validated scale, score, interpretation, and comparison—or why none was applicable;
4. care-plan goal(s), progress, and planning activity;
5. revision made because of nonprogress/status change, or why the current plan remained appropriate;
6. treatment facilitation and coordination action(s), participants, result, and next step;
7. designated care-team member and continuity activity; and
8. author, date, billing practitioner, and source-note references.

8.6 Suggested CoCM documentation structure

CoCM documentation should make the team model visible. In addition to condition, dates, authors, and source references, it should identify:

• the treating/billing practitioner, care manager, and psychiatric consultant;
• registry status and measurement trend;
• the weekly caseload-review process and relevant patient-specific recommendations;
• treating-practitioner disposition and resulting plan changes;
• the brief evidence-based intervention and patient response;
• other-provider coordination; and
• relapse-prevention planning when applicable.

Avoid copying psychotherapy process notes or unnecessarily sensitive content into a billing summary. Document the services and clinical facts needed to support the code while following applicable privacy and recordkeeping requirements.

9. Diagnosis, claims, and concurrent services

9.1 Diagnosis coding

CMS requires an identified behavioral-health condition but does not publish a G0568–G0570 diagnosis list in the reviewed sources. The diagnosis on the claim should accurately represent the condition addressed and follow current ICD-10-CM and payer instructions. Do not advertise an automated F01–F99 problem-list match as a CMS coverage determination.

9.2 One add-on per patient per month

For a patient and calendar month, select no more than one of:

• G0568;
• G0569; or
• G0570.

G0568 and G0569 are mutually exclusive initial/subsequent CoCM choices. General BHI and CoCM are also mutually exclusive for the month.

9.3 Standalone BHI and CoCM codes

The standalone services retain their time requirements:

• 99484 — General BHI, 20 minutes;
• 99492 — initial CoCM, 70 minutes;
• 99493 — subsequent CoCM, 60 minutes; and
• 99494 — additional CoCM time.

CMS also describes G2214, a 30-minute initial-or-subsequent CoCM option, and G0323, a 20-minute General BHI service furnished by a clinical psychologist or clinical social worker. Neither is the APCM add-on analog addressed by this guide. Eligibility to report G0323 does not by itself make a psychologist or social worker eligible to report APCM. See the CMS BHI booklet, pp. 8–10.

99494 is an add-on only to 99492 or 99493; do not report 99494 with G0568 or G0569. More generally, do not reuse the same BHI or CoCM work for both a time-based code and an APCM G-code.

Those thresholds do not apply to G0570, G0568, and G0569 when used with APCM. See 90 FR 49470.

There is a source tension rather than a clean federal answer. The CY 2025 PFS rule expressly allowed 99492, 99493, 99494, 99484, and G0323 concurrently with APCM when all requirements were met and work was not duplicated. The CY 2026 rule then introduced the new G-codes as optional add-ons while saying the CPT analogs retain their time thresholds when reported on a standalone basis outside APCM. CMS has not expressly reconciled those statements. Do not report a standalone analog and its G-code for the same work, and confirm the intended 2026 pairing with the MAC. See the CY 2025 APCM concurrency discussion at PDF pp. 496–498 and 90 FR 49470.

9.4 Other services

CMS's BHI FAQ permits separately reportable psychotherapy, evaluation, or substance-use-disorder services when a practitioner is independently qualified, the service is separately furnished, and the same work is not counted twice. The same no-duplicate-work principle should be applied around the new add-ons. See the CMS BHI FAQ, p. 2.

For the same patient and month, the same practitioner reporting APCM may not also report substantially duplicative chronic care management, principal care management, transitional care management, interprofessional consultation, remote evaluation of recorded patient video or images, virtual check-in, or e-visit services. Another practitioner may report those services when medically necessary. CMS permits concurrent APCM with BHI, community health integration, principal illness navigation and peer support, SDOH risk assessment, remote patient monitoring, and remote therapeutic monitoring, provided work is not duplicated. See the CY 2025 PFS final rule, APCM discussion at PDF pp. 490–498.

The older BHI FAQ's general permission to report BHI with CCM does not override APCM's own same-practitioner base-code restrictions. Organizations must evaluate the APCM base claim as well as the add-on; a behavioral-health add-on does not cure a conflict on the APCM base claim.

9.5 RHCs and FQHCs

CMS permits Rural Health Clinics and Federally Qualified Health Centers furnishing APCM to report these behavioral-health add-ons. CMS instructs that the add-ons are paid at the national nonfacility PFS rate rather than bundled into the RHC AIR or FQHC PPS payment. Consult the current CMS RHC booklet and CMS FQHC booklet for setting-specific billing rules.

10. Scenario guide

Every “may be supported” result assumes medical necessity, all shared prerequisites, complete documentation, the same-practitioner APCM base claim, and the absence of payer-specific edits.

11. Common misinformation and the correct rule

12. Payment and valuation

CMS finalized the codes as directly comparable to their standalone analogs. The final-rule preamble stated these crosswalk values:

See 90 FR 49470–49471.

The direct PE figures above are the crosswalk inputs stated in the preamble, not the current calculated PE or total RVUs. The current July 2026 CMS RVU release reflects later practice-expense calculations:

These are national relative values, not guaranteed allowed amounts. Payment depends on the applicable conversion factor, locality GPCIs, facility status, practitioner status, payer processing, sequestration, and other adjustments. Use the current CMS RVU26C release and the Medicare PFS Look-Up Tool for estimates. Patient Part B cost sharing generally applies.

The March 12, 2026 correction recalculated practice-expense values broadly but did not change these code descriptors, the same-practitioner/same-month rule, the non-time-based policy, or the documentation standard. See the CY 2026 correcting document.

13. Questions the federal sources do not fully answer

These are appropriate MAC or payer questions. They should not be presented as settled CMS rules:

1. How exactly do the BHI one-year and APCM three-year initiating-visit tests interact? The safest course is to satisfy both independently, but CMS has not reconciled them in add-on-specific guidance.
2. May a video telehealth visit satisfy the BHI initiating visit? The guidance says face-to-face and does not clearly resolve the virtual case. Audio-only should not be assumed sufficient.
3. What happens when the first month of behavioral-health care-manager activity is incomplete? The literal G0568 descriptor ties the code to that first activity month, not the first complete or billed month. CMS does not say which code, if any, applies when the initial bundle is completed or repeated later. Avoid intentionally splitting the initial service and obtain MAC guidance for an incomplete-start history.
4. How should G0568/G0569 restart after gaps? CMS defines the six-month episode endpoint but does not publish detailed restart examples. Episode logic suggests a post-six-month restart uses G0568 only if the full initial service is repeated, but CMS does not expressly state the restart code.
5. Must base and add-on be on one claim or use a particular date of service? The federal policy states same practitioner and same month, not same claim/date.
6. May a practitioner use a standalone time-based BHI/CoCM code while also reporting APCM? The CY 2025 rule expressly allowed it; the CY 2026 rule's “standalone basis, outside” language and new optional add-ons create unresolved tension. CMS has not expressly reconciled the statements.
7. What specific scale is required for a given condition, and when is no scale applicable under G0570? CMS leaves instrument selection and the boundary of “applicable” unresolved and provides no no-scale billing example.
8. What documentation granularity proves weekly CoCM caseload consultation? CMS requires the weekly process but does not prescribe a note count or a minimum number of patient-specific discussions.
9. May one combined record satisfy APCM and BHI consent? CMS does not require two forms but has not expressly approved a combined one. A combined workflow is defensible only when it distinctly captures every disclosure and permission and preserves independent revocation.

14. A source anomaly worth knowing

In the CY 2026 final rule, the Shared Savings Program ACO-assignment primary-care-service list at 90 FR 50016—42 CFR 425.400(c)(1)(x)(B)(19)–(20)—appears to transpose the General BHI and CoCM category labels attached to these code numbers. It is not the HCPCS long-descriptor section. The labels conflict with:

• the exact descriptors earlier in the same final rule;
• the rule's policy discussion;
• CMS's current HCPCS file; and
• CMS's January 2026 BHI booklet.

The consistent, current mapping is:

• G0568 and G0569 = Psychiatric CoCM;
• G0570 = General BHI.

This appears to be a category-label drafting error in that ACO-assignment list, not a substantive reversal of the HCPCS definitions. The current eCFR provision should be read alongside the operative long descriptors and CMS BHI guidance.

15. Pre-bill checklist

Shared check

• Original Medicare FFS policy applies, or the payer's own policy has been verified.
• Patient has an identified behavioral-health condition that clinically warrants BHI.
• APCM base eligibility and all base-service requirements are met.
• Same billing practitioner will report the base and add-on in the same calendar month.
• BHI consent, specialist-consultation permission, and cost-sharing disclosure are documented.
• APCM consent is documented.
• Any required BHI and APCM initiating-visit requirements are satisfied.
• Only one behavioral-health model/code is selected for the month.
• Medical necessity is present.

Monthly service check

• Every required element of the selected code actually occurred this month.
• Every conditional element was completed when its trigger occurred.
• The billing practitioner personally performed aspects of the service.
• Staff and team roles satisfy the selected model.
• If G0568 is selected, this is the first care-manager activity month and the full initial bundle occurred within it.
• The medical record contains dated, patient-specific, retrievable evidence.
• No work is duplicated across separately reported services.
• Diagnosis and claim information accurately represent the service.
• No payer-specific edit or coverage restriction has been overlooked.

If any required service element is missing, billing the APCM base alone may still be appropriate. Do not generate retrospective language that implies care occurred when it did not.

16. Official source set and currentness audit

Only federal CMS and Federal Register sources were used for the substantive guidance in this document.

Controlling rule and corrections

• CY 2026 Medicare Physician Fee Schedule final rule — Federal Register HTML, especially 90 FR 49469–49471.
• CY 2026 PFS final rule — official GovInfo PDF.
• CMS-1832-F rule page.
• March 12, 2026 correcting document. The correction did not alter the G-code descriptors or core billing/documentation policy.
• November 28, 2025 correcting document. It addressed unrelated skin-substitute material and did not affect these codes.

Current code, payment, and educational sources

• CMS HCPCS Quarterly Update and the July 2026 Alpha-Numeric HCPCS file, updated June 17, 2026.
• CMS Behavioral Health Integration Services booklet, January 2026.
• CMS Behavioral Health Integration FAQ, December 5, 2023, still referenced by CMS's current BHI materials.
• CMS Advanced Primary Care Management Services page, current during this review.
• CMS CY 2026 final-rule summary, MM14315.
• CMS July 2026 PFS Relative Value File, RVU26C.
• CMS Rural Health Clinic booklet.
• CMS Federally Qualified Health Center booklet.

Currentness note

CMS published the CY 2027 PFS proposed rule in July 2026. A proposal is not controlling policy, and no finalized CY 2027 rule exists as of this guide's August 12, 2026 review date. This guide therefore states the currently effective CY 2026 requirements and should be re-audited after the CY 2027 final rule, future quarterly HCPCS updates, new CMS FAQs, NCCI edits, or MAC instructions are published.

Maintenance recommendation: Review this guide at least annually and whenever CMS revises the HCPCS file, BHI booklet, APCM page, NCCI files, Physician Fee Schedule rulemaking, or relevant MAC billing articles.