Email UpdatesAs of January 1, 2026, the Centers for Medicare & Medicaid Services (CMS) has changed how the Medicare program allows Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) to bill for integrated behavioral health services.
Background
The two subsystems of CMS billing codes are Current Procedural Terminology (CPT®) codes, developed and managed by the American Medical Association (AMA), and Healthcare Common Procedure Coding System (HCPCS) codes, developed and managed by CMS. While CPT® codes are used by all payers, including commercial insurers, HCPCS codes are used exclusively in Medicare and Medicaid. HCPCS codes are intended to fill gaps that CPT® codes do not cover.
There are many behavioral health integration (BHI) billing codes for Medicare services. For example, programs implementing the Collaborative Care Model (CoCM) may use CPT® codes 99492, 99493, and 99494 and HCPCS code G2214. Programs practicing general BHI services may use CPT® code 99484 and HCPCS code G0323.
Update
Until recently, Medicare and many state Medicaid programs instructed FQHCs and RHCs to bill CoCM services using HCPCS code G0512 rather than the standard CoCM or general BHI codes. Recent research conducted by the Bowman Family Foundation shows that this requirement may have driven low use of BHI services at FQHCs and RHCs. To address this concern, G0512 has been discontinued as of January 1, 2026. With this change, FQHCs and RHCs practicing CoCM are instructed to bill Medicare using CPT® codes 99492, 99493, and 99494 and HCPCS code G2214. This change allows FQHCs and RHCs to apply the 50%+1 rule when billing for some BHI services. This billing change only applies to Medicare services. Clinics billing for Medicaid services should continue following their state’s Medicaid billing policies.
The 50%+1 rule allows an organization to bill for a code when it completes a majority of the time requirement for the associated service. For example, CPT® code 99492 is the billing code used for the first month of CoCM services and requires 70 minutes of clinical services. When the 50%+1 rule is applied, the clinic must provide at least 36 minutes of service to bill the code. Because G0512 was a bundled care-management code, the 50%+1 rule did not apply.
The clarity provided in the 50%+1 rule ensures that clinics provide the majority of the required service and allows clinics to accommodate patients with more complex needs who may benefit from additional clinical time beyond the base service. Notably, the rule does not apply to the CPT® code associated with general BHI (99484).
Additional Resources
For further information, see these CMS resources:
- HCPCS webpage: More information on HCPCS codes and a list of active HCPCS codes (maintained and updated annually)
- Behavioral Health Integration Services booklet: Detailed information on Medicare BHI billing practices
- Medicare & Mental Health Coverage booklet: Information about Medicare mental health coverage, more broadly
- Rural Health Clinics Center webpage: Resources for RHCs
- Addressing & Improving Behavioral Health webpage: More information on CMS’ behavioral health priorities
See these resources from programs featured in the Integration Academy’s BHI Ecosystem and Directory:
- Advancing Integrated Mental Health Solutions (AIMS) Center: Free monthly Collaborative Care Office Hours and Basic Coding for Integrated Behavioral Health Care fact sheet
- AMA (lead organization of the Behavioral Health Integration Collaborative): Updated Behavioral Health Coding Resource with more information on behavioral health CPT® codes
- The Bowman Family Foundation (BFF): Progress Report on current trends in CoCM in the U.S. and Collaborative Care Service Organizations Directory for more information about organizations that currently practice CoCM