CMS 2026 Physician Fee Schedule: Behavioral Health Billing Changes Explained

New Collaborative Care Model G-Codes: G0568, G0569, G0570

The most consequential change in the CY 2026 PFS for behavioral health is the replacement of the existing Collaborative Care Model (CoCM) CPT codes with three new G-codes. This is not a minor relabeling. The new codes restructure how collaborative care time is documented, billed, and valued.

What Replaced What

The prior CoCM billing framework used three CPT codes introduced in 2017:

• 99492: Initial psychiatric collaborative care management, first 70 minutes in the first calendar month
• 99493: Subsequent psychiatric collaborative care management, first 60 minutes in a subsequent month
• 99494: Initial or subsequent psychiatric collaborative care management, each additional 30 minutes

These codes had persistent confusion in the field around the distinction between initial and subsequent months, the interaction with general behavioral health integration codes, and how to document time across the care team. CMS addressed these issues by creating a cleaner three-code structure:

New Code	Description	Time Threshold	Replaces
G0568	Initial 60 minutes of psychiatric collaborative care management in a calendar month	60 minutes	99492 / 99493
G0569	Initial 30 minutes of general behavioral health integration care management in a calendar month	30 minutes	99484
G0570	Each additional 30 minutes of psychiatric collaborative care or behavioral health integration	+30 minutes	99494

Key Structural Differences

The new structure resolves several longstanding billing ambiguities:

• No initial vs. subsequent distinction: G0568 applies to every month, regardless of whether it is the first month of CoCM services or the tenth. This eliminates the 99492/99493 confusion about when the initial period ends.
• Clear separation of psychiatric CoCM and general BHI: G0568 is specifically for psychiatric collaborative care (requiring psychiatric consultant involvement), while G0569 is for general behavioral health integration that may not include a psychiatric consultant. Under the old structure, the relationship between 99492-99494 and the general BHI code 99484 was a frequent source of coding errors.
• Unified add-on code: G0570 serves as the add-on for both G0568 and G0569, simplifying charge capture. Practices no longer need to determine which add-on applies to which base code.
• Consistent time thresholds: The 60-minute base for G0568 and 30-minute base for G0569 create clean, predictable thresholds that align with how care manager time is typically accumulated.

Who Bills These Codes

CoCM codes are billed by the billing practitioner, typically the primary care physician or the treating psychiatrist who oversees the collaborative care team. The time counted toward these codes includes activities performed by the care manager, the psychiatric consultant, and the billing practitioner. The care manager performs the bulk of the billable activities: systematic tracking and monitoring of patients on the registry, proactive outreach to patients who are not improving, brief interventions using evidence-based techniques, and coordination with the psychiatric consultant. The psychiatric consultant contributes time through registry review, case consultation, and treatment recommendations. All cumulative time across the care team counts toward the monthly threshold.

Digital Mental Health Treatment (DMHT) Device Reimbursement

The CY 2026 PFS expands Medicare coverage and reimbursement for FDA-cleared digital therapeutics used in behavioral health treatment. This is a category that has been growing since FDA began clearing prescription digital therapeutics (PDTs) for substance use disorders, insomnia, and ADHD, but reimbursement pathways have been inconsistent. The 2026 rule establishes clearer billing codes and coverage criteria.

What Qualifies as DMHT

DMHT devices under the PFS are FDA-cleared software-based treatments that deliver evidence-based interventions, most commonly cognitive behavioral therapy protocols, through smartphone or tablet applications. These are distinct from wellness apps and teletherapy platforms. To qualify for DMHT reimbursement, the device must have FDA clearance or authorization specifically for the treatment of a diagnosable condition, must be prescribed by an eligible practitioner, and must deliver a structured therapeutic protocol rather than simply providing information or symptom tracking.

Billing Structure

The expanded DMHT codes cover three phases of the treatment workflow:

• Prescribing and setup: Covers the clinician time for evaluating the patient, prescribing the DMHT device, initial device configuration, and patient onboarding and education on device use.
• Ongoing monitoring: Monthly codes for reviewing patient engagement data, treatment adherence metrics, and clinical outcome measures generated by the DMHT device. This includes the clinical decision-making required to adjust the treatment plan based on device-generated data.
• Discontinuation and transition: Covers the clinical assessment and documentation required when ending DMHT treatment, including transition planning to other modalities.

For behavioral health practices that already use or plan to integrate FDA-cleared digital therapeutics, these codes create a legitimate billing pathway that did not previously exist in a clean form. The practical revenue impact depends on the volume of patients using qualifying devices and the reimbursement rates assigned to the specific DMHT codes, which CMS will update as utilization data matures.

Conversion Factor Update: APM vs. Non-APM Divergence

The CY 2026 PFS conversion factor update introduces a meaningful split between practices participating in Advanced Alternative Payment Models (APMs) and those that are not.

What This Means by Practice Type

The conversion factor split has different implications depending on the type of behavioral health practice:

• Solo therapists (LCSWs, LPCs, psychologists): Most solo practitioners are not in APMs and will see a flat conversion factor. Because these practitioners primarily bill evaluation and therapy codes (90837, 90834, 90791), the flat conversion factor means their Medicare rates are effectively unchanged from 2025. The impact is minimal in dollar terms but represents a real-value decrease when adjusted for inflation.
• Psychiatry practices: Psychiatry practices have more APM participation options, particularly through Primary Care First (which has a behavioral health track) and some ACO models. Practices in qualifying APMs will see the 3.77% increase applied across E/M codes, psychiatric evaluation codes, and medication management services. For a psychiatrist billing 1,500 Medicare encounters per year, the 3.77% increase translates to approximately $4,000 to $7,000 in additional annual revenue.
• Integrated behavioral health in primary care: These settings benefit the most. Primary care practices with integrated behavioral health are more likely to participate in APMs, and the conversion factor increase applies to both the medical and behavioral health services billed by the practice. The CoCM codes (G0568-G0570), psychiatric diagnostic evaluation, and psychotherapy add-on codes all benefit from the higher conversion factor.

Health Behavior Assessment and Intervention (HBAI) Code Updates

The CY 2026 PFS updates the Health Behavior Assessment and Intervention codes (96156-96171), which are used by psychologists, clinical social workers, and other behavioral health practitioners to bill for services focused on health behaviors that affect medical conditions. These are distinct from psychotherapy codes and are used when the presenting issue is a behavioral factor (such as medication non-adherence, lifestyle modification, or adjustment to a medical diagnosis) rather than a primary mental health diagnosis.

What Changed

• Revised time thresholds: The initial assessment code (96156) and intervention codes (96158, 96159, 96164, 96165, 96167, 96168, 96170, 96171) have updated time-based documentation requirements that better align with clinical practice. The minimum time threshold for the initial assessment has been adjusted to reflect realistic clinical encounter lengths.
• Documentation clarification: CMS provided additional guidance on what constitutes adequate documentation for HBAI services versus standard psychotherapy. The key distinction remains that HBAI services must address a health behavior that is complicating or affecting a physical health condition, and documentation must reference both the behavioral intervention and the related medical condition.
• Group HBAI rates: Group intervention codes (96164, 96165, 96170, 96171) received minor rate adjustments that slightly improve reimbursement for group-based health behavior interventions. This is relevant for behavioral health practices that run condition-specific groups (diabetes management, cardiac rehabilitation support, chronic pain coping).

Chronic Pain Management Code Refinements

The CY 2026 PFS refines the chronic pain management and treatment codes (99491, 99437) that were expanded in previous rule cycles. These codes are relevant to behavioral health because chronic pain management increasingly involves behavioral health interventions, and many behavioral health practices serve patients with comorbid chronic pain conditions.

The refinements clarify bundling rules between chronic pain management codes and psychotherapy codes when both are billed on the same date of service or within the same calendar month. Specifically, CMS clarified that chronic pain management codes and CoCM codes can be billed for the same patient in the same month when the clinical focus of each service is distinct and separately documented. This is important for integrated practices managing patients with both chronic pain and behavioral health conditions.

For behavioral health practices that treat the pain-behavioral health overlap population, these refinements provide clearer guardrails for capturing revenue from both the behavioral health and pain management sides of treatment without triggering bundling edits or audits.

What Your Billing Team Needs to Do

The CY 2026 PFS changes require specific, time-bound actions from billing and coding teams. The following action items are prioritized by deadline urgency and revenue impact.

1. Update fee schedules with new G-codes (immediate). Add G0568, G0569, and G0570 to the practice fee schedule with the correct 2026 RVU values. Remove or deactivate 99492, 99493, 99494, and 99484 for dates of service on or after January 1, 2026. Verify that payer-specific contracted rates are loaded for each new code.
2. Retrain coders on the CoCM code structure (immediate). Conduct a focused training session for all coders and billers on the three-code CoCM structure. The most common error will be continuing to use the old CPT codes out of habit. Create a quick-reference card that maps old codes to new codes and post it at every coding workstation.
3. Update EHR charge capture templates (immediate). Modify order sets, charge capture screens, superbills, and any encounter-based pick lists to present the new G-codes instead of the old CPT codes. If the EHR supports code-mapping rules, update the mapping logic to prevent old codes from being selected for 2026 dates of service.
4. Model the CoCM revenue opportunity (within 30 days). For practices with existing or planned collaborative care programs, model the monthly revenue potential using the new G-code rates. Identify the number of patients who qualify for CoCM services, estimate the average monthly care manager time per patient, and calculate the expected monthly billing for G0568/G0569 plus G0570 add-ons. See the revenue impact section below for modeling guidance.
5. Evaluate DMHT device integration (within 60 days). If the practice uses or is considering FDA-cleared digital therapeutics, review the new DMHT billing codes and determine which devices in your workflow qualify for reimbursement. Build the charge capture and documentation workflow for DMHT prescribing and monitoring.
6. Assess APM participation status (within 60 days). Determine whether the practice qualifies for APM participation. If the practice is not currently in an APM, model the revenue impact of the 3.77% conversion factor increase against the operational requirements of APM participation. For practices near the APM qualifying threshold, this may be the year where the conversion factor differential tips the cost-benefit analysis in favor of joining.
7. Update HBAI documentation templates (within 30 days). Revise documentation templates for HBAI codes to reflect the updated time thresholds and CMS documentation guidance. Ensure templates prompt clinicians to document both the behavioral intervention and the related medical condition, which is the most common documentation deficiency on HBAI claims.
8. Review chronic pain management bundling rules (within 30 days). For practices billing both chronic pain management codes and behavioral health codes for the same patients, update internal coding policies to reflect the 2026 bundling clarifications. Create documentation guidelines that clearly distinguish the clinical focus of each service to support separate billing.

Revenue and Financial Impact

The financial impact of the CY 2026 PFS varies significantly by practice type and service mix. Here are concrete estimates for the most common behavioral health practice configurations.

Solo Therapist (LCSW/LPC/Psychologist, Non-APM)

For a solo therapist billing primarily 90837 and 90834 with Medicare, the flat conversion factor means 2026 Medicare rates are effectively unchanged from 2025. If the therapist bills 1,200 Medicare encounters per year at an average reimbursement of $105 per session, total Medicare revenue remains approximately $126,000. The practical impact of the PFS changes is minimal for this practice type, limited to any HBAI code usage.

Estimated annual revenue change: $0 to +$1,500 (HBAI adjustments only).

Psychiatry Practice (3-5 Psychiatrists, APM Participant)

A mid-size psychiatry practice participating in an APM benefits from the 3.77% conversion factor increase across all Medicare PFS services. Assuming combined Medicare billing of $800,000 per year, the conversion factor increase alone generates approximately $30,000 in additional annual revenue. If the practice also operates a Collaborative Care Model with 200 patients, the new G-codes (billed as G0568 monthly plus G0570 add-ons for patients requiring extended care management) could generate an additional $15 to $25 per patient per month, or $36,000 to $60,000 annually.

Estimated annual revenue change: +$66,000 to +$90,000 (conversion factor increase plus CoCM optimization).

Integrated Behavioral Health in Primary Care (APM Participant)

Integrated behavioral health practices within primary care settings see the largest impact because the conversion factor increase applies to the entire practice's Medicare billing, not just the behavioral health services. A primary care practice with integrated behavioral health billing $2 million in annual Medicare PFS services would see a $75,400 increase from the conversion factor alone. Combined with CoCM revenue from G0568/G0569/G0570 for a panel of 300-500 collaborative care patients, the behavioral health integration component could contribute $54,000 to $150,000 in annual revenue.

Estimated annual revenue change: +$129,000 to +$225,000 (practice-wide conversion factor plus CoCM revenue).

EHR and Technology Implications

The CY 2026 PFS changes require specific EHR system updates that go beyond simple fee schedule loading. Practices should verify the following capabilities in their EHR and practice management systems.

• G-code charge capture: Ensure the EHR supports G-codes in charge capture workflows, not just CPT codes. Some older systems or configurations treat G-codes differently from CPT codes in terms of code validation, modifier assignment, and claim routing. Test that G0568, G0569, and G0570 flow correctly from charge capture through claim submission.
• CoCM time tracking: The new codes require cumulative monthly time tracking across multiple care team members. The EHR should support aggregated time logging that accumulates care manager time, psychiatric consultant time, and billing practitioner time against a single patient's monthly CoCM record. Systems that only track time at the encounter level will need workflow modifications.
• Registry management: CoCM requires a patient registry for systematic tracking. The EHR should support registry views showing all active CoCM patients, their current monthly time accumulation, treatment status, and billing eligibility. Platforms like AZZLY Rize that include integrated care coordination tracking can streamline this workflow by connecting clinical documentation directly to billable CoCM activities.
• DMHT device integration: If the practice uses FDA-cleared digital therapeutics, the EHR should support electronic prescribing of DMHT devices, tracking of patient engagement data returned by the device, and linking device-generated outcomes data to the clinical record for documentation and billing support.
• Conversion factor updates: Verify that the practice management system has loaded the correct 2026 conversion factor for your APM participation status. If the system uses a single conversion factor for all providers, practices with some providers in APMs and others not in APMs will need provider-level rate configuration.
• Automated code crosswalk alerts: Configure the EHR to generate alerts or blocks when a user attempts to enter a retired code (99492, 99493, 99494, 99484) for 2026 dates of service. This prevents clean claim failures and reduces rework. For a broader overview of billing codes used in behavioral health, see our mental health billing codes guide.

Frequently Asked Questions

What are the new CoCM G-codes in the CY 2026 Physician Fee Schedule?

The CY 2026 PFS replaces the existing Collaborative Care Model CPT codes 99492, 99493, and 99494 with three new G-codes. G0568 covers the initial 60 minutes of psychiatric collaborative care management in a calendar month. G0569 covers the initial 30 minutes of general behavioral health integration care management in a calendar month. G0570 is an add-on code for each additional 30 minutes of either psychiatric collaborative care or behavioral health integration services. These G-codes took effect January 1, 2026, and practices must update charge capture templates and fee schedules to reflect the new codes.

How does the 2026 conversion factor change affect behavioral health reimbursement?

The CY 2026 PFS conversion factor includes a 3.77% increase for practices participating in Advanced Alternative Payment Models (APMs). Practices not participating in APMs receive a flat conversion factor with no increase. For behavioral health practices, this means psychiatry groups and integrated behavioral health practices participating in APMs will see meaningful rate improvements, while solo therapists and small practices outside of APMs will see stable but flat reimbursement. The differential creates a financial incentive for behavioral health practices to explore APM participation.

What are DMHT codes and how do they affect behavioral health billing?

DMHT stands for Digital Mental Health Treatment. The CY 2026 PFS expands reimbursement for FDA-cleared digital therapeutics used in behavioral health treatment. These are prescription digital devices that deliver cognitive behavioral therapy, substance use disorder interventions, or other evidence-based treatments through software applications. The expanded codes allow providers to bill for prescribing, setting up, and monitoring patient use of these devices, creating a new revenue stream for practices that integrate FDA-cleared digital therapeutics into their treatment protocols.

Do the new CoCM codes pay more or less than the old 99492-99494 codes?

The new G-codes are designed to be budget-neutral relative to the prior CPT codes. G0568 is valued comparably to the combined 99492/99494 under the old structure, and G0569 is valued comparably to 99493. The key difference is structural: the new codes clarify the distinction between psychiatric collaborative care and general behavioral health integration, and the add-on G0570 provides a more flexible mechanism for billing additional time. Practices with strong CoCM programs may see a modest revenue increase due to clearer billing pathways.

How should practices update their EHR systems for the 2026 PFS changes?

Add the new G0568, G0569, and G0570 codes to the charge master and fee schedule with correct RVU values. Retire or deactivate CPT codes 99492-99494 for 2026 dates of service. Update charge capture templates, order sets, and quick-pick lists. Update any automated billing rules or code-mapping logic referencing the old CoCM codes. Add DMHT device codes if the practice uses qualifying digital therapeutics. Verify that time-tracking workflows capture the minutes needed to support the new code thresholds.

What is the revenue opportunity of CoCM codes for a psychiatry practice?

For a psychiatry practice participating in a Collaborative Care Model, the new G-codes represent a monthly recurring revenue opportunity of approximately $15 to $25 per patient per month for qualifying patients. A mid-size psychiatry practice managing 200 CoCM patients could generate $36,000 to $60,000 in additional annual revenue from these codes alone. The revenue opportunity is most significant for practices that already have care manager infrastructure but have been under-billing CoCM services due to confusion about the old code structure.

Editorial Standards

Last reviewed: February 26, 2026

Methodology

• CoCM code analysis based on CMS-1807-F final rule text, RVU tables, and CMS fact sheets published with the CY 2026 PFS
• Conversion factor calculations derived from CMS-published conversion factor tables and APM qualifying criteria for CY 2026
• Revenue modeling estimates based on Medicare PFS allowed amounts, practice-level billing volume benchmarks, and CoCM program operational data
• DMHT reimbursement framework sourced from CMS final rule preamble discussion and FDA digital therapeutics clearance database
• HBAI and chronic pain management code updates verified against CMS Transmittal notices and Medicare Claims Processing Manual updates

Primary Sources

• CMS CY 2026 Physician Fee Schedule Final Rule (CMS-1807-F)
• Federal Register: Medicare and Medicaid Programs; CY 2026 Payment Policies Under the PFS
• APA Practice Resources: Medicare Reimbursement
• CMS Medicare Learning Network: Collaborative Care Model