Because the U.S. healthcare system continues its shift towards complete, entire‑particular person care, the Facilities for Medicare & Medicaid Providers (CMS) is expanding payment models to higher assist built-in main and behavioral Health companies. In 2026, CMS launched new behavioral Health integration (BHI) and psychiatric collaborative care administration (CoCM) add‑on codes designed to strengthen the Advanced Primary Care Management (APCM) mannequin launched in 2025.
This month’s FWA Insights highlights what particular investigation items (SIUs) ought to know in regards to the new add‑on codes, how they differ from earlier necessities, and the potential vulnerabilities to errors, upcoding, and fraud that Health plans could encounter as suppliers adapt to the up to date billing construction.
Background: CMS rolls out APCM
In 2025, CMS applied Superior Main Care Administration (APCM) as a brand new care‑administration program aimed toward supporting primary care teams treating sufferers with power and complicated circumstances. APCM was constructed on a month-to-month care‑coordination framework and required suppliers to furnish 13 service parts tailor-made to particular person affected person wants. This system marked a strategic transfer away from go to‑based mostly billing towards ongoing longitudinal care.
These new codes shift reimbursement from inflexible, time-based documentation to extra versatile, team-based care. The looser documentation necessities and expanded supplier eligibility create a excessive potential for billing errors, upcoding, and fraud that Health plan SIU groups want to pay attention to.
New APCM code particulars
APCM base codes established in 2025
CMS created three month-to-month APCM base codes—HCPCS G0556 via G0558—to assist ongoing care coordination for sufferers with various ranges of medical complexity.
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G0556: Providers for sufferers with one or no power circumstances
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G0557: Providers for sufferers with two or extra power circumstances lasting ≥12 months and posing vital threat
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G0558: Providers for Certified Medicare Beneficiary sufferers assembly the identical power‑situation standards as G0557
Not like conventional go to‑based mostly billing, APCM codes symbolize a month-to-month, affected person‑centered method designed to assist lengthy‑time period, relationship‑based mostly care fairly than a invoice per go to. These codes reimburse care groups for month-to-month administration actions like ongoing care coordination, power situation administration, together with transitional care, remedy administration, and addressing medical and social determinants of Health.
New 2026 add‑on codes for BHI and CoCM companies
In 2026, CMS expanded the APCM mannequin and launched three new add‑on HCPCS codes—G0568 via G0570—based mostly on affected person threat and care depth. The intent is for these codes for use together with the APCM base codes when behavioral Health integration and psychiatric collaborative care administration companies are rendered by physicians, practitioners, rural Health clinics (RHCs), and federally certified Health facilities (FQHCs).
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G0568: Preliminary/first month of psychiatric collaborative care administration
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G0569: Subsequent months of psychiatric collaborative care administration
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G0570: Common behavioral Health integration companies
These codes cross‑stroll to CPT codes 99492–99494, however importantly, CMS has eliminated the time‑based mostly necessities beforehand hooked up to these CPT codes. As an alternative, billing is tied to companies rendered, lowering administrative burden and permitting groups to deal with care complexity fairly than time thresholds.
This replace represents a big shift from earlier necessities for RHCs and federally certified Health facilities, which traditionally reported CoCM utilizing the bundled HCPCS code G0512 with CPT codes 99492–99494. As of 2026, G0512 has been deleted, and RHCs/FQHCs should now invoice utilizing the corresponding CPT/HCPCS codes that replicate the particular behavioral Health service delivered. This variation is meant to enhance transparency, accuracy, and alignment of behavioral Health billing throughout care settings.
Transferring ahead
There are a number of key areas of potential FWA vulnerability that stakeholders ought to intently monitor, with probably the most urgent together with:
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Standalone or incorrect billing of add‑on codes: As a result of the brand new BHI and CoCM add‑on codes have been beforehand a part of a single bundled service, there may be heightened threat that they could be billed as standalone companies. Health plans ought to verify that G0568–G0570 are submitted solely alongside an applicable APCM base code and that each the bottom and add‑on codes are billed as soon as monthly, by the identical rendering supplier, with affected person consent correctly documented.
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Unbundling and duplicate billing dangers: APCM codes are supposed to replicate a complete, month-to-month method to care. As such, they shouldn’t be billed together with different care‑administration packages—corresponding to Transitional Care Administration (TCM) or Power Care Administration (CCM)—in the identical service interval. Doing so constitutes unbundling and will end in duplicative or inappropriate cost.
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Lacking or incomplete care‑workforce construction: BHI and CoCM companies depend on coordinated, workforce‑based mostly care involving the treating practitioner, a behavioral Health Care supervisor, and a psychiatric guide. Claims submitted with out proof of this required multidisciplinary workforce symbolize a big vulnerability and warrant additional overview.
As CMS continues refining the APCM mannequin, the introduction of recent behavioral Health add‑on codes represents a significant step towards extra built-in, affected person‑centered care. By eliminating outdated time‑based mostly necessities and changing bundled billing with extra exact coding, CMS goals to higher replicate the true complexity of each behavioral and power situation administration.
For SIU groups, these modifications create an necessary alternative to strengthen oversight, guarantee correct reporting, and assist suppliers in delivering coordinated care that actually addresses sufferers’ entire‑particular person wants. On the identical time, the looser documentation necessities create potential for billing errors, upcoding, and fraud that SIU groups want to repeatedly monitor.
Webinar: Navigating regulatory modifications and FWA schemes in 2026
Dive deeper and keep forward of potential FWA patterns. Don’t miss our newest on-demand Cost Integrity Pulse webinar as we focus on key regulatory modifications and the trending schemes present in Cotiviti information that could be affected by these actions.
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