What is BHI (Behavioral Health Integration)?

Last reviewed May 12, 2026

Definition

Behavioral Health Integration (BHI) is the Medicare reimbursement framework for delivering behavioral health services within a primary care setting, rather than referring patients out to standalone behavioral health providers. It includes the Collaborative Care Model (CoCM, codes 99492, 99493, 99494) and general BHI (code 99484). Beginning CY2026, CMS introduced APCM-aligned BH add-on codes — G0568, G0569, G0570 — that allow practices to bill integrated behavioral health alongside APCM base codes under the same TIN.

The two BHI pathways

CMS recognizes two distinct integrated-behavioral-health payment pathways:

Collaborative Care Model (CoCM) — A specific evidence-based model in which the primary-care practice works with a designated behavioral health care manager and a consulting psychiatric provider to deliver measurement-based, registry-tracked behavioral health treatment within primary care. Codes:

99492 — Initial month of CoCM services (first 70 minutes of behavioral health care manager activities).
99493 — Subsequent months of CoCM (60 minutes).
99494 — Add-on for each additional 30 minutes within a CoCM month.

CoCM has the strongest evidence base of any integrated behavioral health model and is specifically named in CMS payment policy.

General BHI — Code 99484 captures integrated behavioral health activities that do not meet the full CoCM structural requirements (e.g., do not include the formal psychiatric consultant role) but still involve systematic behavioral health care management coordinated with the primary-care team, 20 minutes of clinical staff time per calendar month, directed by a physician or qualified health professional.

The CY2026 APCM-aligned BH add-on codes

In the CY2026 Physician Fee Schedule Final Rule, CMS finalized three new HCPCS codes — G0568, G0569, G0570 — designed specifically to allow practices billing APCM (G0556, G0557, G0558) to also bill integrated behavioral health services for the same patient population. These codes parallel the APCM tier structure and capture behavioral health management activities delivered within an APCM care-management arrangement.

The same-TIN constraint

A defining feature of all BHI codes — including the new G0568-G0570 — is the same-TIN billing requirement. The behavioral health services must be billed under the same Taxpayer Identification Number as the primary care practice billing APCM (or CCM). The PCP entity is the Medicare-billing entity. Behavioral health clinicians who deliver the underlying services do so either as employees of the PCP entity or under a contractual arrangement that satisfies CMS’s “incident-to” and supervision requirements for the relevant codes.

This constraint has practical implications for how primary-care practices structure access to behavioral health capacity, since most primary-care practices do not directly employ the full behavioral health workforce (care managers, consulting psychiatrists, therapists) required to deliver CoCM or general BHI at scale.

Partnership-based implementation

A common implementation pattern is the partnership-based model — sometimes referred to as the Concert Health Model B pattern in the integrated behavioral health literature — in which a primary-care practice contracts with a dedicated behavioral health partner organization to provide the clinical infrastructure (behavioral health care managers, consulting psychiatric providers, registry technology, measurement-based care workflows) needed to deliver BHI services. Under this pattern:

The PCP practice remains the Medicare-billing entity. All BHI claims are submitted under the PCP TIN.
The behavioral health partner provides clinical staff and infrastructure under a fixed, fair-market-value Management Services Agreement (MSA).
Payment between the PCP and the BH partner is structured as a fixed administrative fee, not as a share of Medicare reimbursement, to align with CMS anti-kickback and Stark Law guidance.

This structure preserves the same-TIN billing requirement, provides the PCP practice with behavioral health clinical capacity it would otherwise have to build internally, and keeps the financial arrangement compliant with federal fraud-and-abuse rules.

Why BHI matters in the APCM context

Primary-care panels carry substantial unmet behavioral health need — depression, anxiety, substance use disorder, and behavioral comorbidities of chronic disease are well-documented in the primary-care literature. The CY2026 alignment of behavioral health add-on codes with APCM signals CMS’s intent that integrated medical and behavioral care management become the standard primary-care arrangement, not a separately structured program. For practices already billing APCM, adding G0568-G0570 captures behavioral health activities that, in most panels, are already being attempted in some form without dedicated reimbursement.

For a deeper treatment of the strategic value of APCM + BHI integration, see The Value of APCM + BHI Integration.

Primary sources

Centers for Medicare & Medicaid Services. CY2017 Medicare Physician Fee Schedule Final Rule — initial CoCM and general BHI code finalization.
Centers for Medicare & Medicaid Services. CY2026 Medicare Physician Fee Schedule Final Rule — APCM-aligned BH add-on codes G0568-G0570.
CMS Behavioral Health Integration MLN factsheets (current revisions).
CPT code descriptors for 99492, 99493, 99494, 99484. HCPCS Level II descriptors for G0568, G0569, G0570.

For the base care-management framework, see What is APCM?. For the integration strategy, see The Value of APCM + BHI Integration. For the predecessor framework, see What is CCM?.