Care Management

Behavioral Health Integration

Table of Contents

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BHI Overview

As of 1/1/2017, Medicare makes separate payments to physicians and nonphysician practitioners for BHI services that they furnish to beneficiaries over a calendar month service period.

BHI is a type of care management service that integrates with primary care. The term behavioral health refers to the promotion of well-being and the prevention and treatment of mental health and substance use concerns. BHI is known as an umbrella term that includes mental health, substance abuse conditions, life stressors and crises, stress-related physical symptoms and health behaviors. 

The integration of behavioral health and general medical services has been proven to be an effective strategy for improving outcomes for millions of Americans with mental or behavioral health conditions. 

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Eligible Conditions

The eligible conditions for BHI are classified as any mental, behavioral health, or psychiatric condition being treated by the billing practitioner, including substance use disorders, that, in the clinical judgment of the billing practitioner, warrants BHI services.

The diagnosis could be either pre-existing or made by the billing practitioner and also may be refined over time. Also, beneficiaries may, but are not required to have, comorbid, chronic, or other medical condition(s) that are being managed by the billing practitioner.

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Part B Billing/Coding BHI Services 

CMS created a code to describe general care management services for patients with behavioral health conditions, which incorporates some but not all of the principles associated with collaborative care.

CPT 99484 is used to bill monthly services furnished using BHI models of care other than CoCM that also includes the following “core” service elements: 

  • At least 20 minutes of clinical staff time spent per calendar month 
  • An initial assessment and monitoring, using validating rating scales 
  • Care planning and care plan revisions for patients whose condition is not improving adequately
  • Facilitating and coordinating treatment such as psychotherapy, pharmacotherapy, counseling and/or psychiatric consultation
  • A continuous relationship with a designated care team member

Keep in mind, CPT 99484 may be used to report models of care that do not involve a clinical staff, a psychiatric consultant, or a designated behavioral health care manager. 

Although, the BHI service period is one calendar month, it’s not required to wait to bill the services. This is due to the fact that CMS anticipates the billing practitioner would continue furnishing services during that month, if it is medically necessary and even after the time threshold to bill BHI is met. After the completion of the minimum clinical staff service time requirements for billing are met, the practitioner may submit the claim and does not need to hold the claim until the end of the month. 

Note: BHI and CoCM are not allowed to be billed for the same beneficiary within the same calendar month. 

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New Coding and Payment for BHI Conditions Billed by Clinical Psychologists and Clinical Social Workers

With the 2023 FR, a new G code was created to describe General BHI performed by CPs or CSWs to account for monthly care integration where the mental health services furnished by a CP or CSW are serving as the focal point of care integration.

The core service elements that must be included in order to bill HCPCS G0323 includes the following:  

  • At least 20 minutes spent per calendar month providing services and meet all of the following required elements which include:
    • Initial assessment or follow-up monitoring, including the use of applicable validated rating scales
    • Behavioral healthcare planning in relation to behavioral/psychiatric health problems, including revisions for patients who are not progressing or whose status changes
    • Facilitating and coordinating treatment such as psychotherapy, coordination with and/or referral to physicians and practitioners whom Medicare authorizes to prescribe medications and furnish E/M services, counseling and/or psychiatric consultation and 
    • Ongoing care with a designated member of the care team.

CPs are authorized, based on their statutory benefit category, to furnish and bill for services provided by clinical staff incident to their professional services when all incident-to requirements are met. However, as CMS highlighted in the 2023 FR, CSWs are only authorized to bill Medicare for services they furnish directly and personally. Also, since CPs and CSWs can’t bill for E/M services, CMS has indicated that CPT 90791 is the best option to serve as the initiating visit.

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Initiating Visit

An initiating visit is required for new patients or beneficiaries not seen within one year prior to commencement of BHI services. 

This visit is important since it establishes the beneficiary’s relationship with the billing practitioner, it ensures the billing practitioner assesses the beneficiary prior to initiating BHI services and discusses BHI w/ the beneficiary during the face-to-face visit.

BHI must be initiated by the billing practitioner during a “comprehensive” E/M visit, annual AWV, TCM or IPPE. 

This face-to-face visit is not part of the BHI service and can be separately billed.

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Supervision Guidelines

BHI services that are not personally performed by the billing practitioner are assigned general supervision under the MPFS.

Although general supervision does not, by itself, comprise a qualifying relationship between the billing practitioner and the other members of the care team. General supervision is defined as the service being furnished under the overall direction and control of the billing practitioner, and his or her physical presence is not required during service provision. 

To improve access to behavioral health services and reduce existing barriers, CMS has made an exception on supervision requirements. Per the 2023 FR, CMS allows auxiliary personnel such as LPCs and LMFTs to provide services under general supervision incident to a physician or NPP.

Auxiliary personnel are defined as any individual who meets the following criteria:

Is acting under the supervision of a physician (or another practitioner), regardless of whether the individual is an employee, leased employee, or independent contractor of the physician (or another practitioner) or of the same entity that employs or contracts with the physician (or another practitioner).

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Advance Consent 

Advance consent is required prior to commencement of BHI services.

The beneficiary must give the billing practitioner permission to consult with relevant specialists, which would include conferring with a psychiatric consultant. 

The billing practitioner must inform the beneficiary that cost sharing applies for both face-to-face and non-face-to-face services that are provided, although supplemental insurers may cover cost sharing. Consent may be verbal (written consent is not required) but must be documented in the medical record.

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Billing BHI and Chronic Care Management in Same Month 


BHI codes can be billed for the same patient in the same month as CCM as long as:

  • Advance consent for both services is received and documented
  • All other requirements to report BHI and CCM are met
  • Time and effort are not counted more than once

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Related Content

Revised 8/1/2024