Why CoCM and BHI Billing Is Growing, and What 2027 Could Change

Updated October 2026. Written by Matteo Grassi, clinical psychologist and cofounder of HANA Health.

Behavioral health integration (BHI) is a set of Medicare monthly care management services that put behavioral health support inside the practice that already treats the patient, through either the Collaborative Care Model (CoCM) or general BHI. Between 2018 and 2024, Medicare CoCM services rose from 55,082 to 284,062 and general BHI services from 24,033 to 473,156.

From the clinical side, the number I'd watch isn't the code count. It's whether a trained person reaches the patient every month.

Key facts

• Medicare CoCM services rose from 55,082 in 2018 to 284,062 in 2024, about 5.2 times, according to Blunt et al., JAMA Network Open (2026).
• General BHI (CPT 99484) services rose from 24,033 to 473,156 over the same years, about 19.7 times, in the same study.
• Those totals are lower bounds, because the data hide cells with 1 to 10 services, and the study can't separate more practices from heavier use by existing ones.
• Medicare added CoCM codes in 2017, 99484 in 2018, G2214 in 2021 and G0323 in 2023, per the CMS Report to Congress on BHI outreach (2024).
• On January 1, 2026, CMS added optional add on codes G0568, G0569 and G0570 for use with advanced primary care management, per the CMS BHI booklet (January 2026).
• For CY 2027, CMS proposed raising the work RVU of 99492 from 1.88 to 2.75 and the care manager labor rate from $0.57 to $0.70 a minute, per the ACP summary of the proposed rule (2026).
• A Cochrane review (2012) pooled 79 randomized trials with 24,308 participants and found collaborative care beat usual care for depression and anxiety.

Why is general BHI growing faster than CoCM?

General BHI grew about 19.7 times between 2018 and 2024 while CoCM grew about 5.2 times, and the codes' entry requirements are the most plausible reason. In absolute terms, BHI added 449,123 services and CoCM added 228,980. Compound growth works out to about 64% a year for BHI and 31% a year for CoCM. That's our arithmetic from the Blunt et al. counts.

The cost of entry is very different. General BHI code 99484 needs at least 20 minutes of clinical staff time a month and no psychiatric consultant. CoCM needs a three person team, a registry and a weekly caseload review with a psychiatric consultant. Here are the thresholds, per the CMS BHI booklet:

• 99484: at least 20 minutes of clinical staff time a month. Assumed billing practitioner time is 15 minutes.
• G0323: at least 20 minutes of clinical psychologist or clinical social worker time a month.
• 99492: 70 minutes of care manager time in the first month. Assumed practitioner time is 30 minutes.
• 99493: 60 minutes in each later month. Assumed practitioner time is 26 minutes.
• 99494: each additional 30 minutes, added to 99492 or 99493.
• G2214: 30 minutes of care manager time, for months that fall short of the CoCM thresholds.

A lower bar probably explains part of the gap. It's an inference, though. The study counted services, not reasons, so "plausibly" is the strongest word the data allow.

What rule changes made room for this growth?

CMS has added a new payment pathway for behavioral health integration every few years, and each one lowered a barrier for practices. The sequence below comes from the CMS Report to Congress and the CMS BHI booklet.

1. CY 2017 final rule: separate payment for CoCM codes 99492 to 99494.
2. CY 2018 final rule: payment for general BHI code 99484.
3. CY 2021 final rule: G2214, a 30 minute CoCM code for months that miss the base thresholds.
4. CY 2023 final rule: G0323, a general BHI code for clinical psychologist or clinical social worker time.
5. January 1, 2026: optional add on codes G0568, G0569 and G0570. They aren't time based, and you bill them in the same month as an APCM base code (G0556, G0557 or G0558).

Only the first four sit inside the 2018 to 2024 window, and the study counts only some of them. Its CoCM series includes G2214 from 2021, and its BHI series is 99484 alone, so G0323 isn't in either. The 2026 add ons are too new to show up at all. That means you can't tie the growth to any single rule change.

What does the evidence say about collaborative care?

CoCM has a strong trial base for depression and anxiety, but the effects are small to moderate, and the evidence doesn't cover every code that's growing. The 2012 Cochrane review pooled 79 randomized trials with 24,308 participants. Depression improved more with collaborative care than with usual care in the short, medium and long term. The short term standardized mean difference was 0.34 in favor of collaborative care (95% confidence interval 0.27 to 0.41). Anxiety results pointed the same way.

The benefit wasn't shown at the very long term for depression (risk ratio 1.12, 95% confidence interval 0.98 to 1.27).

Three limits matter for billing:

• The review searched trials up to February 2012, before Medicare paid for any of these codes.
• The trials tested structured collaborative care, not the CPT time thresholds.
• General BHI covers models of care other than CoCM, so the trial base doesn't map neatly onto 99484.

A rising code count doesn't prove patients are getting the model the trials tested.

What does the CY2027 proposal change for CoCM payment?

In July 2026, CMS proposed raising the work value of every CoCM code and the labor rate for behavioral health care managers, but nothing is final. The proposal is in CMS-1848-P (91 FR 43842), with a CMS fact sheet. Comments closed September 14, 2026, and CMS usually issues the final rule in early November.

Here are the proposed work RVU changes from the ACP summary, with our percentages:

• 99492: 1.88 to 2.75, up 0.87 or about 46%.
• 99493: 2.05 to 2.26, up 0.21 or about 10%.
• 99494: 0.82 to 1.13, up 0.31 or about 38%.
• G2214: 0.77 to 1.13, up 0.36 or about 47%.

CMS also proposed raising the care manager labor rate from $0.57 to $0.70 a minute. It valued physician work on a blend of level 3 and level 4 visits, not the level 4 and 5 blend that stakeholders asked for.

Now the arithmetic for 99492. Today's national office payment is the total of 1.88 work, 2.78 practice expense and 0.14 malpractice RVUs, which is 4.80. Multiply by the $33.4009 conversion factor and you get $160.32, per the CMS 2026 fee schedule data. The work change alone adds 0.87 RVUs, about $28.57 at the proposed $32.84 conversion factor. But practice expense inputs shift too, and CMS proposed cutting that conversion factor 1.68% from $33.40. So the final dollar rate isn't knowable yet. Don't budget on it.

What can't the growth numbers tell you?

They can't tell you how many practices adopted CoCM or BHI, how many patients were reached, or whether these are the fastest growing Medicare care management services. That last claim is why this article doesn't make it. The study doesn't compare these codes with other care management families.

The authors name the limits. Totals are lower bounds, because cells with 1 to 10 services were suppressed. Services couldn't be linked to unique clinicians or patients, so growth could mean broader adoption, heavier use by existing practices or a changing patient mix. The data also leave out federally qualified health centers, Medicare Advantage and commercial payers.

The paper's own focus was oncology. Oncologists billed less than 1% of CoCM and BHI services each year, so the national totals mostly describe other specialties.

Growth from a small base can look dramatic. It's real growth in billing. It isn't proof that most eligible patients now get integrated care.

What this means for your practice

Pick the model your staffing can run, then bill only what your documentation supports.

• If you don't have a psychiatric consultant or a registry, general BHI is the lighter place to start. Our BHI guide covers consent and the initiating visit.
• If you can protect a weekly consultant slot and keep a registry, our CoCM billing guide walks through the minutes and consent.
• If you bill APCM, check whether the 2026 add on codes fit your workflow.
• Don't build a 2027 budget on proposed values. Wait for the final rule.

The hard part is rarely the code. It's reaching patients every month and documenting the work. HANA Health works with practices on the outreach and follow up calls that sit around Medicare care management programs, and you can see how on the HANA Health practice page.

Frequently asked questions

Is general BHI the same thing as the Collaborative Care Model?

No. CMS describes CoCM as a team model with a billing practitioner, a behavioral health care manager and a psychiatric consultant. General BHI uses care models other than CoCM, with no psychiatric consultant required.

Can a practice that bills APCM also bill CoCM or BHI?

Yes, from 2026, through the optional add on codes G0568, G0569 and G0570. You bill them in the same month as an APCM base code, and they aren't time based. Read the rule text before you adopt them, because they're new.

Will CoCM pay more in 2027?

It might, but it's only proposed. CMS proposed higher work RVUs and a higher care manager labor rate, and it also proposed a lower conversion factor. The final rule decides.

Do the 2018 to 2024 numbers describe oncology practices?

Mostly not. The paper's focus was oncology, but the totals are national. Oncologists accounted for under 1% of each service.

Does faster growth mean more patients are getting collaborative care?

Not necessarily. The data count services, not patients, and the authors say they can't tell broader adoption from heavier use at existing practices.

Sources

1. Blunt K, Johns K, McAlearney AS, Miller LE. Trends in Medicare Billing by Oncologists for Integrated Mental Health Care Services. JAMA Network Open, 2026. doi.org/10.1001/jamanetworkopen.2026.0023
2. Centers for Medicare & Medicaid Services. MLN909432, Behavioral Health Integration Services, January 2026. cms.gov
3. Centers for Medicare & Medicaid Services. Report to Congress, Provider Outreach & Reporting on Certain Behavioral Health Integration Services, September 2024. cms.gov
4. Centers for Medicare & Medicaid Services. CY 2027 Medicare Physician Fee Schedule Proposed Rule fact sheet, July 14, 2026. cms.gov
5. Federal Register. CY 2027 Payment Policies Under the Physician Fee Schedule, CMS-1848-P, 91 FR 43842, July 16, 2026. federalregister.gov
6. American College of Physicians. Summary of the CY 2027 Physician Fee Schedule Proposed Rule, 2026. acponline.org
7. Archer J, Bower P, Gilbody S, et al. Collaborative care for depression and anxiety problems. Cochrane Database of Systematic Reviews, 2012. cochrane.org
8. Centers for Medicare & Medicaid Services. Physician Fee Schedule data, 2026 indicators, updated October 2026. pfs.data.cms.gov

This article is educational and isn't billing, coding, clinical or legal advice. Check current CMS guidance and your MAC before you bill. If you'd like to talk through how a behavioral health program could run in your practice, book a discovery call.