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Behavioral Health Billing Guidelines for Providers

Jon-Michial Carter
Written by Jon-Michial Carter

Due to the national shortage of mental health professionals and logistical, financial, and cultural obstacles, the primary care provider may be the sole setting in which a patient engages with their behavioral health.  The Centers for Medicare & Medicaid Services (CMS) recognizes the positive impact that Behavioral Health Integration (BHI) and has created opportunities for practices to expand their revenue* by providing and billing for behavioral health services, like psychological assessments, depression screenings, and substance abuse coaching. 

If a practice performs billing correctly, practices can be subsequently reimbursed for rendering these instrumental services to their patients. BHI services can be billed alongside other care management services, like Chronic Care Management (CCM)

Incorporating behavioral health into your medical practice provides an invaluable opportunity to partner with mental health professionals, psychiatric services, and substance abuse counselors to integrate behavioral care into a patient’s wellness plan. 

Research demonstrates that behavioral interventions can not only improve a patient’s mental health symptoms, like by alleviating feelings of depression, but also have long-lasting implications on a patient’s overall clinical prospects. 

As the broader healthcare discourse expands into the mental health arena, healthcare providers must understand the complexities and nuances of CPT billing codes for BHI services to maximize their practice’s potential and improve patient care. In this article, we will explore the details of BHI billing to help your practice ensure you’re rewarded for the valuable care you provide your patients.  

What is a Behavioral Health Integration (BHI) program?

Behavioral Health Integration (BHI) program is a healthcare strategy uniting primary care services, care management services, and mental, behavioral, and psychiatric care. BHI programs close the gap between physical and mental health by offering a suite of services under the roof of one practice. 

For example, a patient’s primary care doctor may notice that a patient is demonstrating signs of mental distress and subsequently include a mental health screening during a routine office visit. They can then share these results with an in-house mental health professional, who can follow up with the patient and schedule additional appointments to address any identified issues further. This approach eliminates barriers to entry for patients, ensures continuity of care, improves care coordination and clinical outcomes, and erases the fragmentation of care that causes many patients to become overwhelmed or disengaged with healthcare services.   

What conditions are covered by Behavioral Health Integration?

Some of the most common examples of conditions that fall under the umbrella of behavioral health include but are not limited to: 

  • Depression
  • Anxiety
  • Attention-Deficit/Hyperactivity Disorder (ADHD)
  • Bipolar Disorder
  • Post-Traumatic Stress Disorder (PTSD)
  • Schizophrenia and other psychotic disorders
  • Suicidal ideation
  • Substance use disorders, including alcohol misuse and drug dependence
  • Destructive behaviors, like gambling addiction

CMS has not provided specific definitions or restrictions for what qualifies as a behavioral service. However, in their 2023 guidelines, their definition of a behavioral health service includes any “diagnosis, evaluation, or treatment of a mental health disorder, including a substance use disorder.” 

This includes services like alcohol misuse screenings, substance abuse interventions and counseling, screenings for common mental health illnesses like depression and anxiety, referrals to external services and treatments, and any psychiatric diagnostic evaluations. It also includes care management services targeting mental and behavioral health conditions. 

Billing for BHI services can be complex due to the broad nature of services offered, the diversity of associated interventions and treatments, and the relative newness of the initiative. The specific services covered by CMS may vary, and practices should pay close attention to patient eligibility and all CMS documentation and guidelines for administering and billing BHI services affiliated with these conditions. 

Since BHI is still young, it’s critical for practices to regularly check CMS for any updates that could affect the administration and reimbursement of BHI services in a primary care setting. 

Behavioral health billing for General BHI vs. Collaborative Care Management (CoCM) 

CMS currently reimburses practices for two types of BHI services: General BHI services and Collaborative Care Management (CoCM) services. While the services complement each other, they are distinct in their execution and use different CPT codes.

Both General BHI and CoCM services include a systematic assessment of the patient’s existing behavioral conditions and the subsequent creation of a personalized care plan designed to address identified behavioral concerns. Both services include ongoing monitoring of the patient’s progress with their care plan, sustaining a relationship with a dedicated care team member, and care coordination of behavioral health services. However, General BHI services contain fewer billing requirements compared to CoCM services.  

CoCM includes additional services by a designated psychiatric consultant or behavioral health care manager assigned to each patient’s care plan. These care managers must have a professional background and certification in a field such as psychology, nursing, or social work. 

CoCM services also include more proactive patient monitoring through telehealth or in-person evaluations. CoCM services are generally more deliberately designed and ensure patients with complex mental and behavioral health issues can access structured and consistent care from trained professionals over extended time frames. It is important to note that General BHI and CoCM cannot be billed in the same month for the same patient. 

Learn more: The Difference between Care Managers vs. Case Managers. 

Can practices bill for BHI and Chronic Care Management services?

Yes, both General BHI and CoCM services can be billed alongside Chronic Care Management (CCM) services, as long as the time and activities being billed are not counted toward both BHI and CCM services. 

For example, you must independently record 20 minutes of BHI services and 20 minutes of CCM services every month to receive reimbursements for both CCM and BHI (totaling 40 minutes of care management services). Providers need to determine program eligibility separately and obtain distinct patient consent for each service. Since certain services qualify for both CCM and BHI billing, the provider should bill the service under the program that most specifically describes the services rendered. 

Learn more: Chronic Care Management Guide for Providers

Guidelines for Behavioral Health Integration billing codes

BHI billing codes generally fall under three categories: initiating visits, General BHI services, and CoCM services. All practices must use the appropriate code for the patient’s initiating visit and introduction to BHI services. Afterward, practices should use the codes that correlate with the behavioral healthcare model dispensed by their care management team.*

*This is intended as guidance only. Codes may change over time, so it’s important to consult the latest CMS guidelines

Behavioral Health billing codes

The list below includes many common billing codes used for a patient’s initiating visit but is not exhaustive. Patients must have an initiating visit if they have not been seen within one year before the start of their BHI services. These can include an Initial Preventive Physical Exam (IPPE, also known as the one-time Welcome to Medicare visit), a Medicare Annual Wellness Visit (AWV), Transitional Care Management (TCM) services, or other qualifying evaluation or care management services. These services are billed under the traditional visit code for the performed service and do not need to be otherwise adjusted.

  • G0402 (Welcome to Medicare / Initial Preventive Physical Exam)
  • G0438 (Initial Annual Wellness Visit)
  • G0439 (Subsequent Annual Wellness Visits)
  • G0468 (FQHC IPPE or AWV)
  • 99495 & 99496 (Face-to-Face Transitional Care Management Services)
  • 99202-99205 (Levels 2-5 E/M Visits)
  • 90791 (Psychiatric Diagnostic Interview)

Providers must deliver a comprehensive IPPE, AWV, TCM, or E/M visit that includes an explicit discussion of BHI with the patient during the visit. Otherwise, those services cannot count as the patient’s initiating visit for BHI.

What are the General BHI billing codes?

99484 (General Behavioral Health Integration for Care Management Services)

CPT code 99484 is the BHI billing code for care management services administered for general behavioral health integration services. Code 99484 requires at least 20 minutes of dedicated behaviorally focused care per patient monthly. 

To bill under code 99484, a provider must adhere to the core principles of General BHI. This includes facilitating an ongoing relationship between the patient and their dedicated care manager and coordinating behavioral health services. 

Under General BHI, providers and care managers design, review, and revise behavioral health care plans based on continued patient assessment and observation. CPT code 99484 can be billed in tandem with Chronic Care Management services. 

G0323 (General BHI Billing for Licensed Independent Social Workers & Clinical Psychologists)

To alleviate the strenuous workload on physicians, licensed independent social workers and clinical psychologists can bill for BHI services as of 2023. The billing requirements for G0323 are identical to those of CPT code 99484, requiring 20 minutes of care management services per month. 

Though a social worker or clinical psychologist provides these services, CMS emphasizes that the primary care provider's role should remain central to the patient’s care and wellness plans. However, by expanding the scope of who can bill for BHI services, CMS hopes to encourage greater adoption of General BHI.

G0511 (Care Management for Rural Health Clinics and Federally Qualified Health Centers)

For RHCs and FQHCscode G0511 is used to bill 20 minutes of dedicated care management services per month. This includes both Chronic Care Management services and General Behavioral Health Integration services. If the practice meets the requirements for code 99484, these services can be billed under that code. 

What are the CoCM BHI billing codes?

99492 (Initial Psychiatric Collaborative Care Management)

Code 99492 is used to bill a patient’s initial 70-minute behavioral health consultation through CoCM. This consultation should be directed by a patient's provider or a licensed healthcare professional in collaboration with a psychiatric consultant. In this consultation, care management teams should create an individualized care plan for the patient. Patients will subsequently engage directly with their dedicated care manager and care team members on their care plan progress. 

99493 (Follow-Up Psychiatric Collaborative Care Management)

After the initial visit, all subsequent CoCM BHI sessions must be billed under code 99493. This covers the required 60-minute check-ins with the patient’s dedicated care management team. In these sessions, a patient’s progress with their BHI wellness plan will be monitored and adjusted to meet the patient’s needs. 

99494 (Additional Time for Initial and Subsequent Psychiatric Collaborative Care Management)

Code 99494 is billed in tandem with CPT codes 99492 and 99493 for an additional 30 minutes of behavioral healthcare services provided to a patient during Collaborative Care Management sessions. Each additional 30 minutes per calendar month of care manager activities directed by a provider and psychiatric consultation are eligible for billing. 

G2214 (Additional Time for Initial and Subsequent Psychiatric Collaborative Care Management)

HCPCS code G2214 bills initial or subsequent CoCM BHI care management services. G2214 was introduced in 2021 in response to requests for more nuanced billing codes. G2214 captures shorter intervals of time spent delivering behavioral healthcare to a patient that does not fit in other existing codes. For example, a patient may be seen for services but then hospitalized or taken to a specialty service, reducing the number of minutes spent with the patient and failing to meet the billing threshold previously established by CMS. 

Who can bill for Behavioral Health Integration services?

Physicians and non-physician practitioners can bill for BHI services under CPT codes 99492, 99493, 99494, and 99484. Per CMS’s guidelines, the billing practitioner should be involved in performing aspects of the General BHI services. This could be the primary care physician, clinical staff members of the practice, or individuals contracted through a “third party” to assist the practice in delivering BHI services. Per CMS’s guidelines, the billing practitioner should be involved in evaluation & management (E/M) services and not strictly relegated to administrative or clerical roles. 

For CoCM services, it is understood that at least three individuals are working in conjunction to provide behavioral healthcare to the patient–the provider, the psychiatric consultant, and the behavioral healthcare manager. Only one practitioner may provide and bill for all Behavioral Health Integration services for General BHI. 

Why are mental health services important for Medicare patients? 

The Medicare population is uniquely at risk for social isolation and loneliness, which contribute to depression and anxiety and are linked to chronic illness. Patients dealing with multiple chronic conditions are more at risk for poorer care coordination, which can leave them feeling abandoned by the greater healthcare industry. When left untreated, mental health conditions exacerbate physical conditions, discourage proactive patient engagement, and lead to additional complex health problems. This costs patients more money, demands more time and resources from overburdened practices and hospitals, and results in overall poor optimization and worsened quality of care. 

A primary care setting is an ideal place to engage patients on their mental health and equip them with resources to manage it and a support team to assist them in their journey. Through BHI, Medicare patients are proactively engaged in caring for their mental health in the same way they are encouraged to participate in preventative cancer screenings, bloodwork, and diagnostic tests. 

Additionally, 12.7% of Medicare spending goes toward mental health services or other medical services associated with mental illness. This should not come as a surprise when considering the prevalence of co-existing chronic conditions among the Medicare population, alongside the daunting challenges that accompany these diagnoses. Access to mental healthcare also encourages productivity and community contribution and reduces the risk of substance abuse and alcohol misuse.

As the healthcare industry works to destigmatize mental health treatment, especially among an older population with potentially less exposure to these concepts, BHI functions as an invaluable in-road to extending these services to the Medicare population.

Integrate transformative Behavioral Health solutions through ChartSpan

ChartSpan is a national leader in compassionate and effective Chronic Care Management services. We understand the vital role mental health plays in every patient’s wellness and clinical prospects and can assist your practice in incorporating Behavioral Health Integration alongside our turnkey CCM program. 

ChartSpan fosters supportive environments, personalized wellness plans, and positive clinical outcomes for patients through Chronic Care Management and behavioral health. Patients can rely on our team of care managers for assistance, encouragement, and accountability through every step of their physical or mental care. 

Our expert team is eager to aid your practice in implementing behavioral health services and help your practice open an additional revenue channel. Together, we can close gaps in care, eliminate barriers to mental healthcare access, and promote higher patient satisfaction.  

Contact us to learn more about how ChartSpan can help your practice offer transformative BHI solutions. 

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*Results may vary by provider. 

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