The Centers for Medicare & Medicaid Services (CMS) has proposed significant updates for Calendar Year (CY) 2026 to enhance behavioral health services within primary care. The proposal introduces optional add-on codes under Advanced Primary Care Management (APCM) services in efforts to strengthen the integration of behavioral health care and streamline administrative processes for providers.
Three New G-Codes
As part of the proposal, CMS plans to establish three new HCPCS G-codes, which would serve as add-on services that may be billed when an APCM base code is reported by the same practitioner in the same month. The services covered by these codes are designed to be directly comparable to existing Behavioral Health Integration (BHI) and psychiatric Collaborative Care Model (CoCM) codes.
Reducing Administrative Burden
CMS proposes the removal of time-based requirements currently associated with BHI and CoCM codes. CMS believes that eliminating these requirements will reduce the documentation burden for providers, making it easier for primary care physicians to furnish behavioral health services. This change is expected to encourage greater adoption of BHI and CoCM practices, expanding access to comprehensive care.
Designated Care Management Services
The proposed add-on codes would be classified as “designated care management services.” Under this designation:
- The services could be provided by auxiliary personnel under the general supervision of the billing practitioner.
- This flexibility would also apply to Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs), helping to extend behavioral health services to underserved areas.
How Providers Can Prepare for the Proposed Changes
By creating these new add-on codes, CMS hopes to facilitate the delivery of complementary behavioral health services within primary care settings, reduce administrative and documentation barriers as well as improve patient access to integrated behavioral healthcare. Although the changes from CMS are still in the proposal stage, providers can still take proactive steps now and position themselves for successful implementation through the following best practices:
- Review Current BHI and CoCM Processes – Evaluate how your practice currently integrates behavioral health services and identify documentation or workflow challenges that may be eased by the removal of time-based requirements.
- Update Internal Policies – Prepare to align practice policies with the new CMS guidelines once finalized and plan for revisions to billing and coding procedures to include the new G-codes.
- Train Staff and Auxiliary Personnel – All clinical staff should be trained to understand the new flexibility regarding who can deliver designated care management services and the proper use and documentation of APCM add-on services.
- Assess Technology and Billing Systems – Confirm that your electronic health records (her) and billing software can accommodate the new codes. Work with your billing teams to develop efficient and effective workflows for accurate and timely claims submission.
- Strengthen Behavioral Health Integration –
Build or enhance collaborative relationships with behavioral health specialists, and develop protocols to streamline care coordination under the APCM model.
What’s Next
If finalized, the changes proposed by CMS can help primary care practitioners more effectively address the mental health needs of their patients while minimizing administrative strain. However, as with any change, the help of a trusted advisor can aid in the implementation of best practices. Windham Brannon’s Healthcare Consulting Team is poised to help you prepare for upcoming changes with a strategy that is tailored for your unique organization. For questions or more information, contact your Windham Brannon advisor today, or contact Denise Gaulin.
