The Centers for Medicare & Medicaid Services (CMS) has reimbursed primary care practices for providing behavioral health services to Medicare beneficiaries since 2018. That’s when the American Medical Association (AMA) and CMS first introduced Current Procedural Terminology (CPT*) codes for behavioral health integration (BHI) services.
Initially, CMS reimbursed for General BHI services using CPT code 99484 and Psychiatric Collaborative Care Management (CoCM) services using CPT codes 99492, 99493, and 99494. Amid increased demand for integrated behavioral health services, CMS has since started reimbursing practitioners for services covered under Healthcare Common Procedure Coding System (HCPCS) codes G2214, G0323, and G0511. (HCPCS codes are a subset of CPT codes.)
These billing codes give practices an opportunity to support patients’ behavioral health needs in a familiar care setting as part of their overall care management to support the goals of integrated behavioral health care. Because each CPT and HCPCS code comes with different requirements, it’s important for practitioners to know which codes are appropriate for the services they provide.
The CPT code for general behavioral health integration services is 99484: Care management services for behavioral health conditions, at least 20 minutes of clinical staff time, directed by a physician or other qualified health care professional, per calendar month.
This billing code reflects services such as systematic assessment and monitoring, care plan revision, and collaboration with members of the care team.
Meanwhile, there are three CPT codes for Psychiatric CoCM services:
What is the difference between 99492 and 99484? The key difference between CPT codes 99492 and 99484 is the CoCM model. Services billed to CPT code 99492 must be delivered as part of a Psychiatric CoCM model, while services billed to CPT code 99484 may be delivered as part of any care model. Additionally, the Psychiatric CoCM care team consists of the billing practitioner, a psychiatric consultant, and a behavioral health care manager with specialized training in behavioral health (including social work, nursing, or psychology); the General BHI care team includes the billing practitioner and may include those who meet the qualifications of a behavioral health care manager.
CMS documentation indicates providers shouldn’t bill CoCM and General BHI CPT codes in the same calendar month for a single Medicare beneficiary. That said, CMS advises “it may be appropriate” to report multiple codes over the course of several months.
In 2018, CMS also introduced separate CPT codes for behavioral health integration services provided by federally qualified health centers and rural health centers. HCPCS code G0511 is for general services, while HCPCS code G0512 is for Psychiatric CoCM services. Use of this code will reimburse providers at a higher rate, reflecting the value proposition for behavioral health services in rural and underserved areas.
The World Health Organization estimates one in seven adults over 60 years old lives with a mental health condition. Older adults face multiple risk factors for poor mental health, including ageism, social isolation, bereavement, declining physical health, and increasingly limited functional ability.
The pandemic only exacerbated these risk factors. WHO data estimates 80% of people who have died from COVID-19 are over 60. Older adults are far more likely to have lost close friends and loved ones. The stress of coping with unexpected loss has contributed to increased demand for mental health services. In turn, that has led to increased workloads, longer waitlists, and greater burnout among practitioners, according to an American Psychological Association survey.
In response to increased demand, CMS introduced HCPCS code G2214 in 2021: Initial or subsequent psychiatric collaborative care management, first 30 minutes in a month of behavioral health care manager activities, in consultation with a psychiatric consultant, and directed by the treating physician or other qualified health care professional.
According to CMS, this billing code is meant to capture shorter increments of time spent with a patient under Psychiatric CoCM services. For example, a patient may be seen for behavioral health services and then referred for specialized care or hospitalization. In that situation, the encounter is unlikely to be long enough to meet the time requirements of CPT codes 99492 (70 minutes) and 99493 (60 minutes).
To further expand access to care, CMS updated its mental health services billing guide in 2023 with a CPT code for behavioral health integration and care management services billed by additional practitioners.
The new HCPCS code is G0323: Care management services for behavioral health conditions, at least 20 minutes of clinical psychologist or clinical social worker time, per calendar month.
Practitioners can think of HCPCS code G0323 the same way they view CPT code 99484. Both are intended for general BHI services, not for Psychiatric CoCM services. As the American Psychological Association points out, the updated CMS mental health services billing guide 2023 allows psychologists to be reimbursed for their time as members of the integrated behavioral health services care team.
As CMS continues to expand reimbursement options for behavioral health integration services, primary care practices will have additional opportunities to serve as a trusted source of care for Medicare beneficiaries with behavioral health needs. Identifying who would benefit from BHI and CoCM services and effectively coordinating their care can be a challenge for practices that are unprepared. To find out more about how the Proem workflow solution supports the delivery of BHI, book a meeting.
* CPT is provided "as is" without warranty of any kind, either expressed or implied, including but not limited to, the implied warranties of merchantability and fitness for a particular purpose. No fee schedules, basic unit, relative values or related listings are included in CPT. The AMA does not directly or indirectly practice medicine or dispense medical services. The responsibility for the content of this file/product is with Proem and no endorsement by the AMA is intended or implied.
