Picture a family medicine practice that added a licensed clinical social worker two years ago to help with the depression and anxiety that fills a third of every schedule. The social worker is busy all day. The practice bills almost nothing for her time, because nobody set up the collaborative care codes and the physicians assumed the work was bundled into the visit. We see this pattern more often than any other in primary care coding reviews, and the assumption is wrong. Medicare and most commercial payers have paid for behavioral health integration since 2017, and the rates are meaningful when the program is run properly.
This article covers the two models, the codes, the time rules, the documentation, and the ways we see these claims fail. It is written for the coder and the practice manager who have to make the program pay for itself, not for the clinician designing the care model.
Key takeaways
- Two models, five codes: CoCM (99492, 99493, 99494 and, for Medicare, G2214) needs a care manager, a psychiatric consultant and a registry; general BHI (99484) needs neither the consultant nor the registry.
- The codes are monthly, the month is the calendar month, and only care manager time counts toward the CoCM thresholds. Bill the threshold you met and do not round up.
- Six things have to be in the chart: consent with cost-sharing disclosure, an initiating visit, a care plan, a per-patient time log, consultant review notes and rating scale results. The time log is what fails audits.
- The billing practitioner is the treating physician or qualified practitioner, never the care manager, and coinsurance applies, so tell the patient at enrollment.
- A care manager with 60 to 80 active patients usually covers her salary and the consultant contract, but only if every month's minutes are logged per patient.
Two models, five codes
Collaborative Care Model (CoCM) requires three roles: the treating practitioner (usually the primary care physician or NP), a behavioral health care manager, and a psychiatric consultant who reviews the caseload with the care manager at least weekly and advises on treatment. The care manager maintains a registry and uses validated rating scales (PHQ-9, GAD-7) to track response.
General Behavioral Health Integration (BHI) is the lighter model: the treating practitioner and clinical staff provide assessment, care planning and follow-up under a care plan, without the required psychiatric consultant or registry structure.
| Code | Model | Time per calendar month | Notes |
|---|---|---|---|
| 99492 | CoCM, first month | First 70 minutes of care manager time | Initial assessment, registry entry, consultant review, care plan |
| 99493 | CoCM, subsequent months | First 60 minutes | Ongoing tracking, consultant review, treatment adjustments |
| 99494 | CoCM add-on | Each additional 30 minutes | Reported with 99492 or 99493 |
| G2214 | CoCM, Medicare | First 30 minutes, initial or subsequent month | For months that do not reach the 99492 or 99493 threshold |
| 99484 | General BHI | At least 20 minutes of clinical staff time | Cannot be billed in the same month as CoCM codes for the same patient |
The billing practitioner is the treating physician or qualified practitioner, not the care manager or the psychiatric consultant. The consultant is typically contracted and paid by the practice; the consultant does not bill Medicare for the caseload review. Cost sharing applies, which means the patient owes coinsurance on a service they may never have seen delivered face to face. Tell them at enrollment. This is the single most common reason patients disenroll and the single most common source of complaints to the front desk.
What has to be in the chart
- Consent. Verbal consent is acceptable but must be documented, including that the patient was told about cost sharing and that other providers may be involved. Once per episode of care, not every month.
- The initiating visit. For new patients or those not seen within a year, an E/M visit, annual wellness visit or similar face-to-face service by the billing practitioner in which the referral to the program is made.
- The care plan. Behavioral health assessment, diagnosis, goals, planned interventions, and the rating scale baseline.
- Time. A log of care manager minutes per patient per calendar month. Not a monthly total for the program; a per-patient log. This is the item that fails audits.
- Consultant review. Evidence of the weekly caseload review and any recommendations, entered in the registry or the chart, for CoCM months.
- Rating scale results. The PHQ-9 or equivalent, tracked over time, showing that treatment is being adjusted when the patient is not improving.
The time rules, and the arguments about them
CoCM codes are monthly, and the month is the calendar month. Care manager time counts whether it is face to face, by phone, by video, or spent in the consultant review discussing the patient. Time spent by the billing practitioner does not count toward the care manager threshold; the practitioner's own visits are billed separately as E/M.
Whether the CPT midpoint rule applies (reporting 99492 once time passes the midpoint of 70 minutes) is a question payers answer differently, and the safest approach is the one we recommend: document actual minutes, bill the code whose threshold you have met, and use G2214 for Medicare months between 30 and 59 minutes. Do not round up.
A worked month
A 58-year-old patient with moderate depression is referred at a 99214 visit in March. The care manager spends 45 minutes in March on assessment, registry entry and the first consultant review. March is billed as G2214 (Medicare) because 70 minutes was not reached. In April she spends 75 minutes. It is tempting to bill 99493 plus 99494, but 99494 requires a full additional 30 minutes, so April is 99493 alone, and the extra 15 minutes are documented but not billed. In May she spends 95 minutes as the medication is adjusted: 99493 plus 99494. Each month, the claim carries the depression diagnosis (for example F32.1) and is billed under the treating physician.
At roughly $60 for G2214, $140 for 99493 and $60 for 99494 in the Medicare national averages, the three months come to about $400 for one patient, with the patient owing 20 percent. A care manager with a caseload of 60 to 80 active patients generates enough monthly revenue to cover her salary and the consultant contract in most markets. That is the program math, and it only works if the time log exists.
What is new for 2025
The CY 2025 fee schedule added codes that sit alongside BHI: safety planning interventions (G0560, billed in 20-minute increments as an add-on to an E/M or psychotherapy service for patients at risk of suicide or overdose) and a monthly bundle for post-discharge telephonic follow-up after an emergency department visit for a crisis (G0544). It also created payment for digital mental health treatment devices (G0552 to G0554) furnished under a behavioral health treatment plan. None of these replaces CoCM or BHI, but a practice building an integrated program should know they exist.
Denials we see, and why
- 99484 and 99493 in the same month. One model per patient per month. Pick the one that matches the work done.
- No initiating visit on file. Payers look for a qualifying face-to-face service before the first CoCM month. Bill the E/M first.
- Billed under the care manager's NPI. Care managers do not bill these codes. Rebill under the treating practitioner.
- Time not documented per patient. Usually found in audit rather than at adjudication, and the recoupment covers every month reviewed.
- Commercial payer does not recognize G2214. It is a HCPCS code created for Medicare. For commercial payers, bill only 99492 to 99494 and 99484, and know each payer's policy in writing.
- Cost sharing surprise. Not a denial, but the patient refuses to pay and the practice writes off the coinsurance, which is its own compliance problem.
Questions we hear
Can the psychiatric consultant be remote and part time?
Yes. The consultant reviews the registry with the care manager, typically by video or phone, and does not need to see patients. Many small practices contract a psychiatrist for a few hours a week across a shared caseload.
Can an FQHC or RHC bill these codes?
Yes, with their own rules. Beginning in 2025 FQHCs and RHCs bill the individual care management codes to Medicare rather than the former G-code bundles. Read your MAC's guidance before setting up the charge.
Where does a coder learn this properly?
Our live RCM training includes a session on care management and behavioral health integration codes with sample time logs and audit checklists. The Revelrex EHR training environment includes a CoCM registry exercise for the same reason: the documentation is the program.
What to do this month
- Pull twelve months of claims for 99484, 99492, 99493, 99494 and G2214. If the count is near zero and the practice employs a behavioral health clinician or care manager, the program exists but the billing does not.
- Build the per-patient monthly time log in the EHR or the registry, with minutes, date, activity and who performed it. A spreadsheet is acceptable to start; a monthly program total is not.
- Write the enrollment script: what the program is, who is involved, what the patient will owe, and that consent is documented in the chart. Train whoever enrolls patients to use it every time.
- Confirm each of your top commercial payers' policy on 99492 to 99494 and 99484 in writing, and note which ones do not recognize G2214.
- Schedule a ten-chart audit for the end of the second billing month against the six documentation items above, and fix whatever it finds before the program scales.
