CMS Proposes New Behavioral Health Integration Codes for CY 2026

The Centers for Medicare and Medicaid Services (CMS) unveiled its proposed updates to the Medicare Physician Fee Schedule (MPFS) for the calendar year 2026 on July 14, 2025. Among the key proposals are new codes aimed at enhancing behavioral health integration (BHI) and collaborative care management (CoCM) services specifically designed for physicians, practitioners, rural health clinics (RHCs), and federally qualified health centers (FQHCs) that participate in advanced primary care management (APCM) for Medicare beneficiaries.

CMS's proposed rule introduces three optional G-codes—GPCM1, GPCM2, and GPCM3—enabling healthcare providers to bill for additional BHI and CoCM services when reported alongside existing APCM base codes (G0556, G0557, G0558) within the same month. These codes are intended to facilitate the integration of behavioral health services into primary care, thereby improving patient health outcomes and preventing chronic diseases. Notably, these codes can be provided by auxiliary personnel under the supervision of a billing practitioner, reflecting a shift towards a more collaborative care model.

The proposed GPCM1 code aligns with CPT code 99492, which covers the first month of CoCM services, while GPCM2 and GPCM3 correspond to subsequent months and BHI services, respectively. This structure aims to streamline billing practices and enhance the delivery of integrated care. Furthermore, CMS is considering allowing RHCs and FQHCs to utilize these new codes, necessitating adjustments to existing billing policies for CoCM services.

In a significant shift, CMS also proposes to eliminate time-based documentation requirements for both existing BHI and CoCM codes, including the new add-on codes. The agency argues that this removal could enable healthcare providers to offer these essential services without the burden of extensive documentation, thereby fostering a more efficient team-based approach to care coordination.

The proposed changes also affect the definition of 'primary care services' for Medicare Shared Savings Program ACOs. CMS plans to include the new BHI and CoCM codes in this definition, which it believes will enhance the accuracy of beneficiary assignments based on actual care provided. Conversely, the proposal suggests removing the Social Determinants of Health (SDOH) code from the definition, positing that the costs associated with SDOH assessments are already covered by existing evaluation and management services.

CMS is actively soliciting feedback from stakeholders, including interdisciplinary care teams, primary care providers, and ACOs, with comments due by September 12, 2025. Key areas for input include the proposed valuation of the new codes, the impact of documentation changes on care delivery, and whether further adjustments to ACO policies could incentivize primary care providers to participate in the program.

As the healthcare landscape continues to evolve, these proposed changes by CMS mark a critical step towards integrating behavioral health services within primary care settings and improving care coordination for Medicare beneficiaries. The anticipated outcome of these initiatives could lead to higher access to integrated care services, ultimately enhancing patient health and wellbeing in diverse populations. The outcome of the public comments and subsequent adjustments to the proposed rule will likely shape the future of behavioral health integration in the Medicare system.