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FAQ

Behavioral Health Integration

Starting in January of 2017, the Centers for Medicare and Medicaid Services (CMS) approved payment for services provided to patients with behavioral health disorders who are participating in collaborative care services (CoCM) or other behavioral health integration (BHI) services.

The payment structure may be used for patients with any behavioral health condition being addressed by the treating provider, including substance use disorders.
 

Useful online resources describing the CMS Medicare codes include the following:

   • Fact Sheet: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/BehavioralHealthIntegration.pdf
 

   • FAQ: https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched/Downloads/Behavioral-Health-Integration-FAQs.pdf


   • Behavioral Health Services in Primary Care in Primary Care Brochure:  https://www.apa.org/health/behavioral-health-services-primary-care.pdf
 

1. What qualifications are required for the behavioral health care manager role?
 

As noted in the CY 2017 PFS final rule, (81 FR 80231), the behavioral health care manager is a designated member of the care team with formal education or specialized training in behavioral health (which would include a range of disciplines, for example, social work, nursing, and psychology), but Medicare did not specify a minimum education requirement. They may or may not be a professional who meets all the requirements to independently furnish and report services to Medicare. The behavioral health care manager must be available to provide services face-to-face with the beneficiary, have a continuous relationship with the beneficiary, and have a collaborative, integrated relationship with the rest of the care team. He or she must also be able to engage the beneficiary outside of regular clinic hours as needed.

2. For CoCM, must the psychiatric consultant and the billing practitioner be in the same practice? What about the behavioral health care manager and the billing practitioner? The psychiatric consultant and behavioral health care manager may, but are not required to be, employees in the same practice as the billing practitioner.

As noted in the CY 2017 final rule (81 FR 80235), these other care team members are either employees or working under contract to the billing practitioner whom Medicare directly pays for BHI. However, the behavioral health care manager must be available to provide services on a face-to-face basis (though face-to-face services do not necessarily have to be provided). Under the current CoCM model of care, the psychiatric consultant is commonly (but not required to be) remotely located.

3. Can the behavioral health care manager bill for psychotherapy and other similar codes separate from BHI?

Yes. As noted in the CY 2017 PFS Final Rule, (81 FR 80231-80232) if the behavioral health care manager is eligible to independently furnish and report services to Medicare, then that individual could report separate services furnished to a beneficiary receiving BHI services in the same calendar month such as psychiatric evaluation, psychotherapy, and alcohol or substance abuse intervention services. Time spent by the behavioral health care manager on activities for services reported separately could not be included in the time applied to any BHI service code (in other words, time and effort cannot be counted more than once).

4. Can the behavioral health care manager bill for psychotherapy and other similar codes separate from BHI? 

Yes. As noted in the CY 2017 PFS Final Rule, (81 FR 80231-80232) if the behavioral health care manager is eligible to independently furnish and report services to Medicare, then that individual could report separate services furnished to a beneficiary receiving BHI services in the same calendar month, such as psychiatric evaluation, psychotherapy, and alcohol or substance abuse intervention services. Time spent by the behavioral health care manager on activities for services reported separately could not be included in the time applied to any BHI service code (in other words, time and effort cannot be counted more than once). All providers (including the PCP and psychiatric consultant) can bill separately for face-to-face services they provide in conjunction with collaborative care services so long as this time is not included in the calculation of the time spent in providing psychiatric collaborative care services.

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