Georgia Medicare Behavioral Health Integration BHI 2026

By Brevy Care Team · Last verified May 14, 2026

The Medicare Behavioral Health Integration benefit gives every Georgia Medicare beneficiary with a behavioral health condition requiring care management — depression, anxiety, bipolar disorder, post-traumatic stress disorder, substance use disorder, or other diagnosed behavioral health conditions — the right to receive structured behavioral health care management services integrated into the primary care setting. BHI is billed under one of two coding frameworks: (1) the general BHI framework billed under CPT 99484 (20 minutes per calendar month of behavioral health care manager and primary care team time), and (2) the Psychiatric Collaborative Care Model (CoCM) framework billed under CPT 99492 (initial month, 70 minutes), CPT 99493 (subsequent month, 60 minutes), and CPT 99494 (each additional 30 minutes). The CPT codes became effective January 1, 2018 and replaced the HCPCS G0502 (CoCM initial month), G0503 (CoCM subsequent month), G0504 (CoCM add-on), and G0507 (general BHI) predecessor codes that were initially effective January 1, 2017 under the CY 2017 Medicare Physician Fee Schedule final rule (CMS-1654-F, published November 15, 2016).

The Psychiatric Collaborative Care Model is the most evidence-based behavioral health integration model in primary care, rooted in the IMPACT study and a substantial body of subsequent randomized controlled trials demonstrating that team-based care featuring a behavioral health care manager (BHCM) embedded in the primary care setting and a psychiatric consultant providing weekly caseload review through a registry-based population health approach with measurement-based care using validated rating scales produces substantially superior outcomes for depression, anxiety, and other common behavioral health conditions compared to usual primary care management. SAMHSA, the American Psychiatric Association (APA), and the AIMS Center at the University of Washington (which led IMPACT and continues to lead CoCM implementation research) all recognize CoCM as the leading model for integrating behavioral health into primary care. CMS's establishment of the G0502/G0503/G0504 CoCM codes in 2017 and the CPT 99492/99493/99494 successor codes in 2018 created the first dedicated Medicare payment mechanism for the CoCM team-based care model.

For Georgia Medicare beneficiaries, the BHI benefit operates within a state landscape characterized by substantial behavioral health workforce gaps, particularly outside metropolitan Atlanta. Approximately three-quarters of Georgia counties are designated by HRSA as Mental Health Health Professional Shortage Areas (MH-HPSAs), reflecting both an absolute shortage of psychiatrists and a maldistribution of behavioral health providers heavily concentrated in metro Atlanta, Augusta (Augusta University), Macon (Atrium Health Navicent), Savannah (Memorial Health), Athens (Northeast Georgia), and a handful of other urban centers. The BHI framework is particularly important for older Medicare beneficiaries because: (a) older adults face substantially elevated rates of late-life depression often comorbid with chronic medical conditions; (b) older adults are far more likely to seek care in primary care settings than in specialty mental health settings, making primary care integration the natural pathway to behavioral health treatment; and (c) the BHI framework's emphasis on measurement-based care and structured follow-up addresses the underrecognition and undertreatment of late-life depression and anxiety that has historically been documented in primary care settings.

The BHI framework also complements the Medicare care management benefits described in companion guides — Chronic Care Management (CCM) for ongoing multi-condition coordination, Transitional Care Management (TCM) for post-discharge bridge services, and Principal Care Management (PCM) for specialist single-condition management. BHI adds the behavioral health dimension to the care management framework. Beneficiaries with comorbid medical and behavioral health conditions commonly receive BHI alongside CCM, with the two services capturing different but complementary care coordination work performed by different team members.

This guide explains how the Medicare BHI benefit works statutorily and clinically, what eligibility looks like for a Georgia Medicare beneficiary with a behavioral health condition, what the two BHI frameworks (general BHI and CoCM) each require, how the CPT 99484 and CPT 99492/99493/99494 coding works, how the HCPCS G0502/G0503/G0504/G0507 predecessor codes worked from 2017-2017, what the validated rating scale and measurement-based care requirements look like in practice, how the registry-based population health approach operates, how BHI coordinates with CCM, TCM, PCM, AWV, and other care management benefits, what telehealth BHI delivery looks like for rural Georgia beneficiaries, what major Georgia health systems deliver BHI, and why BHI coverage matters for every Georgia Medicare beneficiary with a behavioral health condition requiring care management.

Key Takeaways for Georgia Medicare Beneficiaries

1. CPT 99484 is the general Behavioral Health Integration code effective January 1, 2018, covering at least 20 minutes per calendar month of behavioral health care manager and primary care team time for any behavioral health condition requiring care management. CPT 99484 replaced HCPCS G0507 (effective January 1, 2017).

2. CPT 99492/99493/99494 are the Psychiatric Collaborative Care Model (CoCM) codes effective January 1, 2018: CPT 99492 covers the initial month (70 minutes), CPT 99493 covers subsequent months (60 minutes), and CPT 99494 covers each additional 30 minutes. These codes replaced HCPCS G0502/G0503/G0504 (effective January 1, 2017).

3. Established under CY 2017 MPFS final rule (CMS-1654-F) — CMS established the original G0502/G0503/G0504/G0507 codes in the CY 2017 Medicare Physician Fee Schedule final rule published November 15, 2016, creating the first dedicated Medicare payment for CoCM and general BHI. The CY 2018 MPFS final rule replaced the G-codes with CPT codes effective January 1, 2018.

4. CoCM is the most evidence-based model — The Psychiatric Collaborative Care Model is rooted in the IMPACT study (1999-2003) and a substantial body of subsequent RCTs demonstrating superior outcomes for depression, anxiety, and other behavioral health conditions compared to usual primary care. SAMHSA, APA, and the AIMS Center at the University of Washington recognize CoCM as the leading model for integrating behavioral health into primary care.

5. Team-based care model: CoCM requires three roles — (a) the treating (billing) practitioner, typically a primary care physician or NP/PA; (b) the behavioral health care manager (BHCM) embedded in the primary care setting; and (c) the psychiatric consultant providing weekly caseload review. General BHI requires the treating practitioner plus clinical staff but does not require the psychiatric consultant role.

6. Measurement-based care: BHI requires use of validated rating scales (PHQ-9 for depression, GAD-7 for anxiety, AUDIT for alcohol use, others) with systematic tracking of treatment response and adjustment when patients are not improving.

7. Registry-based population health approach: CoCM operates through a registry tracking all enrolled patients enabling proactive identification of patients not improving and proactive outreach by the BHCM.

8. Patient consent: BHI requires patient consent before furnishing services.

9. Standard Part B cost-sharing: BHI is subject to the Part B deductible and 20% coinsurance, NOT the ACA Section 4104 preventive services cost-sharing waiver. Beneficiaries with QMB dual-eligible status have their cost-sharing covered.

10. Coordination with CCM/TCM/PCM/AWV: BHI can coexist with CCM, TCM, PCM, and AWV in the same calendar month (different services capturing different care coordination work). For Georgia beneficiaries with comorbid medical and behavioral health conditions, BHI + CCM is a common coordinated billing pattern.

The Federal Framework Underlying the Medicare BHI Benefit

HCPCS G0502/G0503/G0504/G0507 — Original BHI Codes Effective January 1, 2017

The Medicare BHI benefit was established effective January 1, 2017 under the CY 2017 Medicare Physician Fee Schedule final rule (CMS-1654-F), published in the Federal Register on November 15, 2016. The CY 2017 final rule recognized that the existing Medicare coding framework did not capture the substantial behavioral health care coordination work performed in primary care settings, particularly in CoCM programs that had been developed and disseminated over the preceding two decades but lacked a dedicated Medicare payment mechanism.

The CY 2017 framework established four G-codes:

• HCPCS G0502 — Psychiatric Collaborative Care Model (CoCM) initial month: Initial psychiatric collaborative care management, first 70 minutes in the first calendar 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, with required elements.

• HCPCS G0503 — CoCM subsequent month: Subsequent psychiatric collaborative care management, first 60 minutes in a subsequent 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, with required elements.

• HCPCS G0504 — CoCM add-on: Initial or subsequent psychiatric collaborative care management, each additional 30 minutes in a calendar 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 (List separately in addition to code for primary procedure).

• HCPCS G0507 — General BHI: 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, with the following required elements: initial assessment or follow-up monitoring, including the use of applicable validated rating scales; behavioral health care planning in relation to behavioral/psychiatric health problems, including revision for patients who are not progressing or whose status changes; facilitating and coordinating treatment such as psychotherapy, pharmacotherapy, counseling and/or psychiatric consultation; and continuity of care with a designated member of the care team.

The CY 2017 G-codes operated for one calendar year before being replaced by CPT codes effective January 1, 2018.

CPT 99484/99492/99493/99494 — Replaced G-Codes Effective January 1, 2018

Effective January 1, 2018, CMS replaced the G0502/G0503/G0504/G0507 G-codes with corresponding CPT codes:

• CPT 99484 (replaced G0507) — 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, with required elements: initial assessment or follow-up monitoring, including the use of applicable validated rating scales; behavioral health care planning in relation to behavioral/psychiatric health problems, including revision for patients who are not progressing or whose status changes; facilitating and coordinating treatment such as psychotherapy, pharmacotherapy, counseling and/or psychiatric consultation; and continuity of care with a designated member of the care team.

• CPT 99492 (replaced G0502) — Initial psychiatric collaborative care management, first 70 minutes in the first calendar 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, with required elements: outreach to and engagement in treatment of a patient directed by the treating physician or other qualified health care professional; initial assessment of the patient, including administration of validated rating scales, with the development of an individualized treatment plan; review by the psychiatric consultant with modifications of the plan if recommended; entering patient in a registry and tracking patient follow-up and progress using the registry, with appropriate documentation, and participation in weekly caseload consultation with the psychiatric consultant; and provision of brief interventions using evidence-based techniques such as behavioral activation, motivational interviewing, and other focused treatment strategies.

• CPT 99493 (replaced G0503) — Subsequent psychiatric collaborative care management, first 60 minutes in a subsequent 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, with required elements: tracking patient follow-up and progress using the registry, with appropriate documentation; participation in weekly caseload consultation with the psychiatric consultant; ongoing collaboration with and coordination of the patient's mental health care with the treating physician or other qualified health care professional and any other treating mental health providers; additional review of progress and recommendations for changes in treatment, as indicated, including medications, based on recommendations provided by the psychiatric consultant; provision of brief interventions using evidence-based techniques; monitoring of patient outcomes using validated rating scales; and relapse prevention planning with patients as they achieve remission of symptoms and/or other treatment goals and are prepared for discharge from active treatment.

• CPT 99494 (replaced G0504) — Initial or subsequent psychiatric collaborative care management, each additional 30 minutes in a calendar 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 (List separately in addition to code for primary procedure).

The CPT 99484 and CPT 99492/99493/99494 codes preserve the foundational structural framework of the G-code predecessors while transitioning to the standard CPT coding framework maintained by the American Medical Association.

Section 1861(s)(2)(B) of the Social Security Act — Physician Services Authority

The underlying statutory authority for BHI payment is Section 1861(s)(2)(B) of the Social Security Act, which authorizes Medicare payment for services furnished by physicians and certain qualified providers. CMS uses its rulemaking authority under the Medicare Physician Fee Schedule to establish BHI-specific codes within the Section 1861(s)(2)(B) framework.

42 CFR 410.26 — Incident-To Framework Supporting BHI

42 CFR 410.26 establishes the Medicare incident-to framework that permits services furnished by clinical staff to be billed under the supervising physician's NPI when furnished under appropriate physician supervision. Both CPT 99484 (general BHI clinical staff time) and CPT 99492/99493/99494 (CoCM behavioral health care manager time) operate under the incident-to framework, with the clinical staff time / BHCM time billed under the treating practitioner's NPI.

The Two BHI Frameworks: General BHI vs. Collaborative Care Model

General BHI (CPT 99484)

The general BHI framework operates as a simpler, more flexible coding option for primary care settings that want to bill for behavioral health care coordination but do not operate a full CoCM program. General BHI requires:

• At least 20 minutes of clinical staff time per calendar month directed by the treating physician/QHP
• Initial assessment or follow-up monitoring including use of applicable validated rating scales (e.g., PHQ-9 for depression, GAD-7 for anxiety)
• Behavioral health care planning including revision for patients who are not progressing or whose status changes
• Facilitating and coordinating treatment such as psychotherapy, pharmacotherapy, counseling, and/or psychiatric consultation
• Continuity of care with a designated member of the care team

The general BHI framework does NOT require the psychiatric consultant role that defines CoCM. The general BHI framework is appropriate for primary care practices that provide behavioral health care coordination but rely on referral relationships to outside psychiatric specialists rather than embedded weekly psychiatric consultation. Many smaller primary care practices, FQHCs, and RHCs use the general BHI framework.

Psychiatric Collaborative Care Model (CPT 99492/99493/99494)

The CoCM framework operates as the comprehensive evidence-based behavioral health integration model requiring three distinct roles operating as a team:

• The treating (billing) practitioner — typically a primary care physician, NP, or PA who serves as the patient's primary medical provider, manages the prescribing for behavioral health medications, and directs the overall behavioral health treatment plan based on recommendations from the psychiatric consultant.

• The behavioral health care manager (BHCM) — a clinician embedded in the primary care setting (typically a licensed clinical social worker, licensed professional counselor, licensed psychologist, advanced practice psychiatric nurse, or similar mental health professional) who serves as the primary point of contact for the patient, conducts initial assessment, performs ongoing care management and brief interventions, tracks patient progress through validated rating scales entered into the registry, and participates in weekly caseload consultation with the psychiatric consultant.

• The psychiatric consultant — a psychiatrist (or, under expanded definitions, a psychiatric advanced practice nurse with appropriate qualifications) who provides weekly caseload review with the BHCM, reviewing the registry-tracked patients, identifying patients not progressing, and making recommendations for treatment adjustments. The psychiatric consultant typically does NOT directly evaluate patients in person — the consultation occurs through review of registry data and consultation with the BHCM, with direct patient evaluation reserved for selected complex cases.

The CoCM framework also requires:

• Validated rating scales — Use of standardized instruments such as the PHQ-9 (depression), GAD-7 (anxiety), AUDIT (alcohol use), DAST (drug use), or other validated instruments appropriate to the condition being treated.

• Registry-based population health approach — Maintenance of a registry tracking all CoCM-enrolled patients including their rating scale scores over time, treatment adjustments, and progress toward treatment goals. The registry enables proactive identification of patients not improving and systematic case review.

• Measurement-based care — Treatment decisions are informed by serial rating scale scores rather than impressionistic clinical assessment alone, with explicit protocols for treatment intensification when patients are not improving.

• Weekly caseload consultation — The BHCM and psychiatric consultant meet at least weekly to review the registry, identify patients requiring treatment adjustment, and make recommendations to the treating practitioner.

• Brief interventions — Evidence-based behavioral interventions delivered by the BHCM including behavioral activation (for depression), motivational interviewing (for substance use and treatment engagement), problem-solving therapy, and other focused brief treatments.

• Outreach and engagement — Proactive contact with patients including phone outreach, motivational interviewing, and structured follow-up to maintain engagement in treatment.

Choosing Between General BHI and CoCM

Primary care practices choose between general BHI and CoCM based on practice capacity and behavioral health workforce availability. CoCM produces superior clinical outcomes per the IMPACT evidence base but requires more substantial infrastructure (embedded BHCM, contracted psychiatric consultant, registry, weekly caseload consultation). General BHI is more accessible to smaller practices and serves a real care coordination function but lacks the structural elements that drive the CoCM outcome advantage.

For Georgia primary care practices considering BHI implementation, the CoCM framework is typically delivered by larger health systems (Emory, Wellstar, Piedmont, academic medical centers) that have the infrastructure to support the BHCM and psychiatric consultant roles, while smaller practices and FQHCs/RHCs are more likely to use the general BHI framework or to participate in larger health system CoCM programs through shared infrastructure arrangements.

The IMPACT Study and the Evidence Base for CoCM

The Psychiatric Collaborative Care Model is rooted in the IMPACT (Improving Mood-Promoting Access to Collaborative Treatment) study conducted between 1999 and 2003 by the University of Washington AIMS Center under the leadership of Dr. Jürgen Unützer. The IMPACT study was a multi-site randomized controlled trial enrolling 1,801 older adults (age 60+) with major depression or dysthymia across 18 primary care clinics in 8 organizations across 5 states. Patients were randomized to either CoCM (intervention) or usual primary care (control), with the primary outcome being depression severity measured at 12 months.

The IMPACT study demonstrated that CoCM produced:

• More than twice the rate of substantial improvement (50%+ reduction in depression symptoms) at 12 months compared to usual care
• Substantially higher rates of antidepressant medication treatment and psychotherapy
• Greater patient satisfaction with depression treatment
• Reduced functional impairment
• Lower healthcare costs over the long term (4-year follow-up showed cost-savings)

Subsequent RCTs have extended the IMPACT findings to additional behavioral health conditions (anxiety, PTSD, substance use disorders, bipolar disorder) and populations (younger adults, perinatal women, veterans, racially/ethnically diverse populations), establishing CoCM as the most evidence-based behavioral health integration model in primary care.

SAMHSA, the APA, and the AIMS Center maintain CoCM as the leading recommended model for integrating behavioral health into primary care. CMS's establishment of dedicated Medicare CoCM payment codes in 2017 and the transition to CPT codes in 2018 represented the most substantial federal payment innovation supporting CoCM dissemination.

The BHI Eligibility Criteria

Behavioral Health Condition Requirement

The foundational BHI eligibility criterion is that the beneficiary must have a behavioral health condition (DSM-5 or ICD-10 diagnosed) that requires care management. Common BHI-eligible conditions include:

• Major depressive disorder (single episode or recurrent)
• Persistent depressive disorder (dysthymia)
• Generalized anxiety disorder
• Panic disorder
• Post-traumatic stress disorder
• Bipolar disorder (I or II)
• Substance use disorders (alcohol, opioid, other)
• Adjustment disorders
• Other DSM-5/ICD-10 diagnosed behavioral health conditions

The condition does NOT need to meet a specific severity threshold — both mild and severe behavioral health conditions can be appropriate for BHI depending on clinical judgment about the patient's care management needs.

Patient Consent Requirement

BHI requires informed patient consent before furnishing services. The consent must address:

• The nature of the BHI services that will be furnished
• The cost-sharing the beneficiary will incur (Part B deductible + 20% coinsurance unless QMB or other coverage)
• The right to refuse or stop BHI services at any time
• Information about who will furnish the services and how communication will work

The consent must be documented in the medical record. Verbal consent is acceptable when documented; written consent is not strictly required but is best practice.

Primary Care Setting Requirement

BHI is structured as a primary care integration benefit, meaning the BHI services are billed by a primary care practice or by a practice operating in a primary care role for the beneficiary. The treating practitioner billing BHI may be:

• A primary care physician (family medicine, internal medicine, general practice, geriatric medicine)
• A nurse practitioner or physician assistant operating in a primary care role
• An OB/GYN providing primary care services
• Certain specialty practices that function as the beneficiary's primary care home

BHI is not typically billed by stand-alone behavioral health providers (psychiatrists, psychologists, social workers in independent practice) — those providers bill different codes for their direct services. BHI is specifically the code framework for integrating behavioral health care management into the primary care medical setting.

The Standard Part B Cost-Sharing Framework

BHI services are subject to standard Medicare Part B cost-sharing:

• Part B deductible — The annual Part B deductible applies before BHI cost-sharing begins. The Part B deductible is $257 for CY 2025 (adjusted annually).

• 20% coinsurance — After the deductible is met, the beneficiary pays 20% of the Medicare-approved amount for BHI services. The Part B cost-sharing applies in both fee-for-service Medicare and Medicare Advantage (though Medicare Advantage plans may structure cost-sharing differently).

• NOT subject to ACA Section 4104 preventive services waiver — Unlike the Annual Wellness Visit, Initial Preventive Physical Exam, and certain screening services, BHI is NOT subject to the ACA Section 4104 cost-sharing waiver for preventive services. Beneficiaries are responsible for the standard Part B cost-sharing.

• QMB and dual-eligible coverage — Beneficiaries with Qualified Medicare Beneficiary (QMB) status under Georgia Medicaid have their BHI cost-sharing covered by Medicaid (Medicare pays the Medicare-approved amount and Medicaid covers the Part B deductible and 20% coinsurance). Other Medicaid Savings Program enrollees (SLMB, QI) do not have BHI cost-sharing coverage but receive Medicare Part B premium assistance.

• Medicare Supplement (Medigap) — Beneficiaries with Medigap coverage have their Part B cost-sharing covered according to their plan structure.

The standard Part B cost-sharing framework means BHI is not free for most beneficiaries, in contrast to AWV and IPPE which are free. This is an important distinction to communicate to beneficiaries during the BHI consent process. For most beneficiaries, the cost-sharing represents a modest amount per month (20% of approximately $50-80 in BHI payment, so $10-16 per month) but the cost-sharing structure does mean beneficiaries should be informed.

The Eligible Providers Furnishing BHI

The following provider types are eligible to bill BHI under Medicare:

• Physicians (MDs and DOs) — primary care physicians, specialty physicians operating in a primary care role
• Nurse Practitioners (NPs) operating within their scope of practice
• Physician Assistants (PAs) operating within their scope of practice
• Clinical Nurse Specialists (CNSs)
• Certified Nurse Midwives (CNMs) providing primary care services

The treating practitioner directs the BHI services. The clinical staff time captured by CPT 99484 (general BHI) and the BHCM time captured by CPT 99492/99493/99494 (CoCM) operates under the incident-to framework, with the time billed under the treating practitioner's NPI.

For CoCM specifically, the BHCM role is typically filled by:

• Licensed Clinical Social Workers (LCSWs)
• Licensed Professional Counselors (LPCs)
• Licensed Marriage and Family Therapists (LMFTs)
• Psychologists (PhD/PsyD)
• Advanced Practice Psychiatric Nurses (PMHNPs)
• Other licensed behavioral health professionals

The psychiatric consultant role in CoCM is typically filled by:

• Board-certified psychiatrists
• Psychiatric advanced practice nurses with appropriate qualifications (under expanded CMS definitions)

The psychiatric consultant does NOT need to be employed by the same practice as the treating practitioner — many CoCM programs operate with contracted psychiatric consultants providing weekly caseload consultation across multiple primary care practices.

The FQHC and RHC BHI Framework

Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can bill BHI services, though the payment methodology differs from standard Medicare Physician Fee Schedule payment:

• FQHC BHI billing — FQHCs bill BHI services under standard CPT codes (99484 general BHI, 99492/99493/99494 CoCM) within the FQHC payment methodology. BHI services are NOT bundled under the FQHC G0511 general care management code that bundles CCM and other care management services. FQHCs can bill BHI separately from G0511.

• RHC BHI billing — RHCs similarly bill BHI services under standard CPT codes within the RHC payment methodology. Like FQHCs, RHC BHI services are not bundled under G0511.

The separate billing pathway for FQHC/RHC BHI services (distinct from the bundled G0511 code that captures CCM) reflects CMS recognition that behavioral health integration represents a distinct care coordination service warranting separate payment recognition even within the FQHC/RHC payment frameworks.

For Georgia, the FQHC network operates approximately 36 FQHC organizations across the state with multiple delivery sites. Many Georgia FQHCs deliver BHI services as part of their integrated behavioral health programming, with the BHI payment supporting the behavioral health care coordination workforce required to operate integrated care models. RHCs operate primarily in rural Georgia, with BHI delivery supported by the BHI coding framework and increasingly by telehealth-based CoCM models leveraging psychiatric consultants based in metropolitan areas.

The Telehealth BHI Framework

Telehealth delivery of BHI services has been substantially expanded under Medicare telehealth flexibilities. Key telehealth BHI considerations include:

• General BHI (CPT 99484) is inherently non-face-to-face work performed by clinical staff and can be delivered without geographic restriction. The clinical staff time can be furnished by clinical staff working remotely from the practice (under appropriate physician supervision via communication technology) and the patient contact components of BHI can be delivered via telephone, video, or other communication technology.

• CoCM (CPT 99492/99493/99494) is similarly inherently non-face-to-face for most components. The BHCM-patient contact can be furnished via telephone, video, or in-person. The weekly BHCM-psychiatric consultant caseload review can be conducted via any communication modality. The registry-based work is by nature non-face-to-face.

• Telephone-only BHI services are explicitly permitted — BHI does NOT require synchronous audio-video telehealth, allowing telephone-only delivery for beneficiaries without video capability.

• Treating practitioner role — The treating practitioner (billing physician/NP/PA) does not need to have direct telehealth contact with the patient as part of BHI billing. The treating practitioner's role is to direct the BHI services, review the BHCM's work, prescribe behavioral health medications when indicated, and coordinate the overall care.

• Geographic flexibility — Standard Medicare telehealth geographic and originating site restrictions historically applied to most telehealth services have been relaxed under the COVID-19 public health emergency flexibilities and subsequent permanent changes for behavioral health services. Mental health services delivered via telehealth do not have the originating site restrictions that applied to other telehealth services under pre-PHE policy.

The telehealth BHI framework is particularly important for rural Georgia where:

• Behavioral health workforce is concentrated in metropolitan areas
• Patients face substantial travel times to access in-person specialty behavioral health care
• Primary care practices in rural counties may lack on-site behavioral health professionals but can partner with metropolitan-area BHCM and psychiatric consultant resources via telehealth

Many CoCM programs in Georgia operate "spoke and hub" models with metropolitan-area health systems providing BHCM and psychiatric consultant resources to rural primary care practices via telehealth-based registry review and weekly caseload consultation. This model substantially extends the reach of CoCM beyond what would be possible if every CoCM program required co-located BHCM and psychiatric consultant resources.

The Coordination Between BHI and Other Care Management Services

BHI and Chronic Care Management (CCM)

BHI and CCM can be billed for the same beneficiary in the same calendar month. The services capture different but complementary care coordination work:

• CCM captures clinical staff time spent on coordination of medical care across the beneficiary's multiple chronic conditions
• BHI captures clinical staff time spent on behavioral health care management specifically

For Georgia beneficiaries with comorbid medical and behavioral health conditions (e.g., diabetes + depression, heart failure + anxiety, COPD + bipolar), the BHI + CCM coordination is the typical structure. The same practice can bill both services in the same month, with the BHI time and CCM time tracked separately and the BHI being directed by the same treating practitioner who directs the CCM (typically the primary care physician).

BHI and Transitional Care Management (TCM)

BHI and TCM can be billed for the same beneficiary in the same calendar month. TCM captures the 30-day post-discharge bridge services while BHI captures the ongoing behavioral health care management. The two services capture different time and care coordination activities and can coexist.

For Georgia beneficiaries discharged from psychiatric hospitalization or with significant behavioral health components of their post-discharge needs, the BHI + TCM coordination supports both the discharge transition and ongoing behavioral health care management.

BHI and Principal Care Management (PCM)

BHI and PCM can be billed for the same beneficiary in the same calendar month when furnished by different practitioners (or by the same practitioner for distinct components of care). PCM captures specialist single-condition disease management while BHI captures the behavioral health integration work.

For Georgia beneficiaries with both a specialist-managed complex chronic condition (e.g., HFrEF managed by cardiology with PCM) and comorbid behavioral health condition (managed via primary care BHI), the coordination supports comprehensive care across the medical and behavioral health dimensions.

BHI and Annual Wellness Visit (AWV)

BHI and AWV can be billed for the same beneficiary in the same calendar month. The AWV includes a depression screening element that may identify a behavioral health condition requiring BHI initiation. The AWV is a single annual visit while BHI is an ongoing monthly service, so the two services capture different work without overlap concerns.

BHI and Direct Behavioral Health Services

BHI is distinct from direct behavioral health services billed by behavioral health providers under their own codes:

• Psychotherapy (CPT 90832, 90834, 90837 individual psychotherapy; CPT 90846, 90847 family therapy; CPT 90853 group psychotherapy) — These are direct psychotherapy services billed by the behavioral health provider furnishing the therapy
• Psychiatric diagnostic evaluation (CPT 90791, 90792)
• Medication management by a psychiatrist (E/M codes plus CPT 90833, 90836, 90838 psychotherapy add-on when applicable)
• Substance use disorder counseling and other behavioral health services billed by behavioral health providers

These direct behavioral health services can occur in parallel with BHI — for example, a beneficiary may receive primary care BHI for medication management coordination by the primary care practice AND psychotherapy from an outside therapist. The services are billed separately and do not duplicate.

The Major Georgia Health Systems Delivering BHI

Emory Healthcare

Emory Healthcare operates one of Georgia's most comprehensive behavioral health integration programs. Emory's primary care network has implemented CoCM and general BHI across multiple primary care clinics with Emory psychiatry providing the psychiatric consultant role. Emory's academic affiliation with the AIMS Center implementation network has supported high-fidelity CoCM dissemination. Emory's geriatric medicine program emphasizes BHI for late-life depression and anxiety in older adults.

Wellstar Health System

Wellstar operates BHI services across its primary care network. Wellstar's behavioral health programming includes integrated care models in selected primary care sites with BHCM-supported care coordination.

Piedmont Healthcare

Piedmont Healthcare delivers BHI services across its primary care network. Piedmont Behavioral Health and Piedmont Eastside Medical Center programs include integrated care components.

Augusta University Health

Augusta University Health operates BHI services with Augusta University psychiatry providing psychiatric consultant resources. The Augusta University academic medical center model supports high-fidelity CoCM in primary care settings affiliated with the medical school.

Atrium Health Navicent

Atrium Health Navicent (Macon) operates BHI services across its primary care network in central Georgia. The Atrium Health system-wide behavioral health integration programming supports BHI delivery.

Memorial Health (Savannah)

Memorial Health operates BHI services in coastal Georgia. The HCA Healthcare affiliation supports system-wide behavioral health integration approaches.

Phoebe Putney Health System

Phoebe Putney delivers BHI services in southwest Georgia. The rural southwest Georgia setting makes BHI particularly important for behavioral health access in a region with substantial workforce shortages.

Northeast Georgia Health System

Northeast Georgia Health System (Gainesville) delivers BHI services in northeast Georgia. Northeast Georgia behavioral health programming includes integrated care components.

Georgia FQHC Network

Georgia's FQHC network delivers BHI services across approximately 36 FQHC organizations operating multiple delivery sites. FQHCs are particularly well-positioned to deliver BHI given their integrated care orientation, behavioral health workforce on-site, and patient populations with substantial behavioral health needs.

Georgia RHC Network

Rural Health Clinics across Georgia deliver BHI services, often through telehealth-based CoCM partnerships with metropolitan health systems. The RHC delivery channel extends BHI reach into rural Georgia counties without on-site behavioral health workforce.

Disease-Specific Applications of BHI in Georgia

Late-Life Depression

Late-life depression is the most common BHI-eligible condition in older adults. BHI for late-life depression typically involves:

• PHQ-9 screening and monitoring — Use of the PHQ-9 (Patient Health Questionnaire-9) as the validated rating scale for depression. PHQ-9 scores are tracked over time with treatment intensification triggered by failure to improve.

• Antidepressant medication management — The treating practitioner (primary care) manages antidepressant prescribing based on PHQ-9 trajectory and psychiatric consultant recommendations in CoCM. Common antidepressants in older adults include SSRIs (sertraline, escitalopram preferred for tolerability), SNRIs (duloxetine, venlafaxine), mirtazapine (often preferred for elderly with insomnia or weight loss), and bupropion.

• Behavioral activation — BHCM-delivered behavioral activation as a core evidence-based brief intervention for depression, involving systematic scheduling of pleasant and meaningful activities.

• Problem-solving therapy (PST) — BHCM-delivered PST as another evidence-based brief intervention well-suited to older adults.

• Coordination with medical comorbidities — Late-life depression often comorbid with heart disease, diabetes, COPD, cancer, and other chronic conditions. The BHI care coordination supports integration of behavioral health treatment with medical care.

Anxiety Disorders

Anxiety disorders in older adults include generalized anxiety disorder, panic disorder, and anxiety associated with medical conditions. BHI for anxiety typically involves:

• GAD-7 screening and monitoring — Use of the GAD-7 (Generalized Anxiety Disorder-7) as the validated rating scale
• SSRI/SNRI medication management with attention to elderly tolerability
• Cognitive behavioral therapy techniques delivered by the BHCM as brief interventions
• Coordination with medical conditions that may mimic or exacerbate anxiety (cardiac arrhythmias, hyperthyroidism, COPD with hypoxia, etc.)

Bipolar Disorder

Bipolar disorder in older Medicare beneficiaries may represent either long-standing illness or late-onset presentations. BHI for bipolar disorder typically involves:

• Mood stabilizer management with attention to elderly considerations (renal dosing for lithium, anticonvulsant interactions)
• Psychiatric consultant involvement (CoCM particularly valuable for bipolar given the prescribing complexity)
• Monitoring for depressive and manic episode recurrence
• Coordination with outside psychiatry when complex bipolar warrants direct psychiatric care

PTSD

PTSD in older adults includes both long-standing combat-related PTSD (particularly relevant for veterans) and trauma from various life events including abuse, accidents, and bereavement. BHI for PTSD typically involves:

• PCL-5 screening and monitoring — Use of the PTSD Checklist for DSM-5 (PCL-5) as the validated rating scale
• SSRI/SNRI medication management
• Trauma-informed brief interventions delivered by the BHCM
• Referral coordination for trauma-focused psychotherapy (prolonged exposure, cognitive processing therapy) typically delivered by outside specialists

Substance Use Disorders

Substance use disorders in older Medicare beneficiaries include alcohol use disorder, opioid use disorder (often complicated by chronic pain management history), benzodiazepine dependence (often complicated by long-term prescribing in older adults), and other substance use. BHI for SUDs typically involves:

• AUDIT screening for alcohol use — Use of the Alcohol Use Disorders Identification Test (AUDIT)
• Brief intervention and referral to treatment (SBIRT) principles
• Motivational interviewing delivered by the BHCM
• Coordination with specialty SUD treatment including medication-assisted treatment (buprenorphine, methadone, naltrexone) when indicated
• Coordination with chronic pain management when opioid use is complicated by pain management history

Rural Georgia Behavioral Health Access Considerations

Approximately three-quarters of Georgia counties are designated as Mental Health Health Professional Shortage Areas (MH-HPSAs) by HRSA, reflecting both an absolute shortage of psychiatrists and a maldistribution heavily concentrated in metropolitan areas. The BHI framework — particularly telehealth-delivered CoCM — represents a critical access pathway for rural Georgia behavioral health needs.

Rural BHI considerations include:

• Telehealth psychiatric consultant — Rural primary care practices can partner with metropolitan-area psychiatric consultants providing weekly caseload review via telehealth. This model extends psychiatric consultant resources across geographic boundaries.

• Telehealth BHCM — When local BHCM workforce is unavailable, telehealth-delivered BHCM services from metropolitan-area health systems can support rural primary care BHI. The patient-BHCM contact can be conducted via telephone or video.

• FQHC and RHC integration — Georgia's FQHC and RHC networks are particularly important for rural BHI delivery given their distribution across rural counties and their integrated care orientation.

• Crisis services coordination — Rural BHI providers coordinate with the Georgia Crisis and Access Line (1-800-715-4225) and the 988 Suicide and Crisis Lifeline for crisis stabilization needs that exceed routine BHI care management.

• CAH coordination — Critical Access Hospitals in rural Georgia coordinate with BHI services for beneficiaries needing higher-acuity care, with BHI supporting continuity of care across hospital and primary care settings.

Six Worked Examples: How BHI Plays Out for Real Georgia Beneficiaries

Example 1: Fulton County 70-Year-Old General BHI for Depression

A 70-year-old woman in Fulton County is enrolled in Emory primary care. Her PHQ-9 score at her Annual Wellness Visit is 14 (moderate-severe depression). Her primary care physician initiates BHI services using the general BHI framework (CPT 99484). The primary care practice does not operate a full CoCM program but employs a clinical social worker who provides care management for behavioral health patients. The clinical social worker conducts initial assessment, administers PHQ-9 monthly, coordinates with the primary care physician on antidepressant management (sertraline initiation), provides behavioral activation as a brief intervention, and facilitates referral to outside psychotherapy. After two months of care management activities totaling 22 minutes in the calendar month, the practice bills CPT 99484. Cost-sharing: Part B deductible (already met from earlier services) plus 20% coinsurance.

Example 2: DeKalb County 75-Year-Old CoCM for Moderate-Severe Depression

A 75-year-old man in DeKalb County is enrolled in Piedmont primary care. His PHQ-9 score is 18 (moderate-severe depression) with comorbid diabetes and hypertension. Piedmont operates a full CoCM program with embedded BHCM and contracted psychiatric consultant. The patient is enrolled in CoCM in the initial month. The BHCM conducts initial assessment, administers PHQ-9, GAD-7, and AUDIT, enters the patient in the CoCM registry, develops a treatment plan reviewed by the psychiatric consultant in weekly caseload consultation, recommends antidepressant initiation (escitalopram), provides behavioral activation and problem-solving therapy as brief interventions, and coordinates with the primary care physician on prescribing. Total BHCM time in the initial month: 75 minutes. Piedmont bills CPT 99492 (initial month CoCM 70+ minutes). Cost-sharing: Part B deductible plus 20% coinsurance.

Example 3: Cobb County 68-Year-Old CoCM Subsequent Month for Anxiety

A 68-year-old woman in Cobb County has been enrolled in Wellstar CoCM for two months for generalized anxiety disorder. Her GAD-7 score has decreased from 16 at enrollment to 11 at month 2. The BHCM continues registry-based tracking, weekly psychiatric consultant caseload review identifies suboptimal response, and the psychiatric consultant recommends increasing the SSRI dose. The BHCM communicates with the treating primary care physician who adjusts the prescription. The BHCM continues brief interventions (cognitive behavioral techniques). Total BHCM time in month 3: 65 minutes. Wellstar bills CPT 99493 (subsequent month CoCM 60+ minutes). Cost-sharing: Part B deductible (already met) plus 20% coinsurance.

Example 4: Worth County 72-Year-Old Rural Telehealth CoCM

A 72-year-old man in Worth County, in southwest rural Georgia, has been newly diagnosed with major depressive disorder during a primary care visit at Phoebe Worth Medical Center. PHQ-9 is 19. The local primary care practice does not have an on-site BHCM but participates in a telehealth-based CoCM program with Phoebe Putney Health System (Albany) providing BHCM services and a contracted psychiatric consultant providing weekly caseload review. The Phoebe Putney BHCM contacts the patient by telephone for initial assessment, administers PHQ-9 and GAD-7, enters the patient in the CoCM registry, develops a treatment plan reviewed by the psychiatric consultant in weekly caseload consultation, recommends antidepressant initiation, and provides brief interventions via telephone. The treating primary care physician in Worth County receives the psychiatric consultant recommendations and adjusts the prescription. Total BHCM time in the initial month: 72 minutes. Phoebe Putney bills CPT 99492. Cost-sharing: Part B deductible plus 20% coinsurance.

Example 5: Bibb County 80-Year-Old CoCM for Bipolar with PCP

An 80-year-old woman in Bibb County has long-standing bipolar II disorder and is enrolled in Atrium Health Navicent primary care. She has been enrolled in Atrium Health Navicent CoCM for six months. In the current month, the BHCM conducts ongoing monitoring with serial mood symptom scales, the psychiatric consultant identifies emerging depressive symptoms warranting medication adjustment, and the BHCM coordinates with the treating primary care physician (who manages the lamotrigine prescription) and with the patient's outside psychiatrist who manages the lithium prescription. Total BHCM time in the calendar month: 95 minutes. Atrium Health Navicent bills CPT 99493 (60 minutes) plus CPT 99494 add-on (additional 30 minutes). Cost-sharing: Part B deductible plus 20% coinsurance.

Example 6: Hall County 74-Year-Old BHI + CCM Coordination

A 74-year-old man in Hall County has multiple chronic conditions (Type 2 diabetes, hypertension, hyperlipidemia, osteoarthritis) plus moderate depression diagnosed during AWV. He is enrolled in Northeast Georgia primary care. The practice enrolls him in BOTH CCM (for the multi-condition care coordination across diabetes, hypertension, and other chronic conditions) AND general BHI (for the behavioral health care management of his depression). Each service is delivered by clinical staff with separate time tracking. In the calendar month, the clinical staff time on CCM totals 25 minutes (medication reconciliation, care plan revision, coordination with endocrinology and cardiology) and the clinical staff time on BHI totals 22 minutes (PHQ-9 monitoring, behavioral activation, antidepressant management coordination, brief intervention). The practice bills both CPT 99490 (CCM) and CPT 99484 (general BHI). Cost-sharing: Part B deductible plus 20% coinsurance on both services.

Fourteen Best Practices for Maximizing BHI Value

1. Document patient consent thoroughly — Maintain documentation of informed BHI consent including disclosure of cost-sharing, the BHI service nature, and the right to refuse. Verbal consent documented in the medical record is acceptable.

2. Use validated rating scales consistently — Apply PHQ-9, GAD-7, AUDIT, PCL-5, or other appropriate validated instruments at initial assessment and at regular follow-up intervals. Track scores in the registry.

3. Operate measurement-based care — Use serial rating scale scores to drive treatment adjustments. Establish protocols specifying treatment intensification when patients are not improving by specified benchmarks (e.g., PHQ-9 not decreased by 50% at 8-12 weeks).

4. Maintain a registry for CoCM — CoCM requires registry-based population health management. The registry tracks all CoCM-enrolled patients including their rating scale trajectories, treatment adjustments, and progress toward treatment goals.

5. Hold weekly caseload consultation — CoCM requires at least weekly BHCM-psychiatric consultant caseload review. The weekly cadence enables proactive identification of patients not progressing and systematic treatment adjustment.

6. Track BHI time meticulously — Document specific BHI activities, who performed them, when they occurred, and the duration. The clinical staff/BHCM time documentation supports the BHI billing.

7. Coordinate with the broader care team — BHI activities should be coordinated with the treating practitioner, other practitioners involved in the patient's care, and outside behavioral health providers when applicable.

8. Build appropriate workforce — For CoCM, identify and recruit BHCM workforce (LCSWs, LPCs, psychologists, PMHNPs) and contract with psychiatric consultants. For general BHI, identify clinical staff who can deliver care management activities under the treating practitioner's direction.

9. Leverage telehealth flexibilities — Use telehealth-delivered BHI components to extend reach including telephone patient contact, video psychiatric consultant consultation, and telehealth-delivered brief interventions.

10. Coordinate with crisis services — Establish protocols for escalating to the Georgia Crisis and Access Line (1-800-715-4225) or 988 Suicide and Crisis Lifeline when BHI patients present with crisis-level symptoms beyond routine care management scope.

11. Coordinate with outside behavioral health — BHI does not replace outside psychotherapy or psychiatric services for patients who need them. Maintain coordination with outside behavioral health providers when applicable.

12. Apply BHI alongside CCM/TCM/PCM — BHI can coexist with CCM, TCM, and PCM in the same calendar month. For multi-morbid beneficiaries, applying the appropriate combination supports comprehensive care coordination.

13. Educate beneficiaries on cost-sharing — Make sure beneficiaries understand that BHI is subject to standard Part B cost-sharing (deductible + 20% coinsurance) and not the preventive services waiver. Identify QMB and Medigap coverage that may offset cost-sharing.

14. Document outcomes for quality reporting — Track BHI patient outcomes including rating scale trajectories, treatment response, hospitalization rates, and other meaningful outcomes. Quality data supports MIPS reporting and demonstrates BHI program value.

Fourteen Common BHI Issues and How to Avoid Them

1. Failure to obtain documented consent — BHI services billed without documented patient consent are at audit risk. Always document the consent discussion.

2. Inadequate time documentation — BHI billing requires specific time documentation. Vague documentation ("provided care management services") is not sufficient. Document specific activities and duration.

3. Failure to use validated rating scales — BHI requires use of validated rating scales as a structural element. Documenting "depression discussed" without a PHQ-9 score is not adequate.

4. Missing weekly psychiatric consultant caseload review for CoCM — CoCM specifically requires weekly BHCM-psychiatric consultant consultation. Missing weeks creates compliance risk.

5. Conflating general BHI and CoCM — General BHI (CPT 99484) and CoCM (CPT 99492/99493/99494) are different services with different requirements. Billing CoCM codes without the structural elements (BHCM, psychiatric consultant, registry, weekly caseload review) is improper.

6. Failure to maintain a registry for CoCM — CoCM requires registry-based population health management. Spreadsheet-only or paper-based tracking is insufficient.

7. Inappropriate use of telehealth without supporting documentation — Document the telehealth modality (telephone, video) and the patient's consent to telehealth-delivered care.

8. Missing measurement-based care actions — Use of rating scales without acting on them defeats the BHI structural purpose. When patients are not improving, document the treatment adjustment.

9. Failing to inform beneficiaries of cost-sharing — Surprise BHI bills create patient relations issues. Ensure beneficiaries understand the cost-sharing before service initiation.

10. Inadequate coordination with outside providers — When patients have outside therapists or psychiatrists, document the coordination with those providers.

11. Missing crisis escalation protocols — When BHI patients develop crisis-level symptoms, the BHI clinical staff/BHCM should have established escalation pathways. Document the escalation when it occurs.

12. Confusing BHI clinical staff time with treating practitioner E/M time — BHI captures clinical staff time / BHCM time. The treating practitioner's separate E/M visits are billed separately as E/M codes.

13. Inappropriate same-practitioner CCM and BHI conflation — While the same practice can bill CCM and BHI in the same month, the time spent on each service must be tracked separately. Double-counting time is improper.

14. Failure to track outcomes — BHI programs that do not track outcomes (rating scale trajectories, treatment response) miss the quality demonstration opportunity and operate without performance feedback.

Frequently Asked Questions

What is Medicare Behavioral Health Integration (BHI)?

Medicare Behavioral Health Integration (BHI) is a set of Medicare-covered services delivering care management for behavioral health conditions integrated into the primary care setting. BHI is billed under either CPT 99484 (general BHI 20 minutes per calendar month) or CPT 99492/99493/99494 (Psychiatric Collaborative Care Model — initial month 70 minutes, subsequent month 60 minutes, add-on 30 minutes). The codes became effective January 1, 2018, replacing HCPCS G0507 (general BHI) and G0502/G0503/G0504 (CoCM) that were originally effective January 1, 2017 under the CY 2017 Medicare Physician Fee Schedule final rule.

When was the Medicare BHI benefit established?

The original BHI codes (HCPCS G0502/G0503/G0504/G0507) became effective January 1, 2017 under the CY 2017 Medicare Physician Fee Schedule final rule (CMS-1654-F, published November 15, 2016). The G-codes were replaced by CPT codes (99484 general BHI; 99492/99493/99494 CoCM) effective January 1, 2018.

What is the difference between general BHI and the Collaborative Care Model?

General BHI (CPT 99484) is a simpler framework requiring at least 20 minutes per calendar month of clinical staff time on behavioral health care management activities. CoCM (CPT 99492/99493/99494) is the comprehensive evidence-based framework requiring a behavioral health care manager (BHCM) embedded in primary care, a psychiatric consultant providing weekly caseload review, a registry-based population health approach, and measurement-based care using validated rating scales. CoCM produces superior outcomes per the IMPACT evidence base but requires more substantial infrastructure.

Who is eligible for BHI?

Any Medicare beneficiary with a behavioral health condition (DSM-5 or ICD-10 diagnosed) requiring care management is eligible. Common conditions include major depressive disorder, generalized anxiety disorder, bipolar disorder, PTSD, substance use disorders, and other behavioral health conditions. There is no specific severity threshold — both mild and severe conditions can be appropriate for BHI based on clinical judgment.

Does BHI require patient consent?

Yes. BHI requires informed patient consent before furnishing services. The consent must address the nature of the services, the cost-sharing the beneficiary will incur, and the right to refuse or stop services. The consent must be documented in the medical record.

What is the cost-sharing for BHI?

BHI is subject to standard Part B cost-sharing: the Part B deductible plus 20% coinsurance. BHI is NOT subject to the ACA Section 4104 preventive services cost-sharing waiver. Beneficiaries with QMB dual-eligible status have their cost-sharing covered by Medicaid. Beneficiaries with Medigap coverage have their cost-sharing covered according to their plan.

Who can bill BHI?

Physicians, nurse practitioners, physician assistants, clinical nurse specialists, and certified nurse midwives can bill BHI when operating in a primary care role. The clinical staff time (general BHI) or BHCM time (CoCM) operates under the incident-to framework and is billed under the treating practitioner's NPI.

What roles are required for CoCM?

CoCM requires three roles: (1) the treating (billing) practitioner — typically a primary care physician, NP, or PA; (2) the behavioral health care manager (BHCM) — typically an LCSW, LPC, psychologist, or psychiatric advanced practice nurse embedded in the primary care setting; and (3) the psychiatric consultant — typically a psychiatrist providing weekly caseload review via consultation with the BHCM. The psychiatric consultant typically does not directly evaluate patients in person.

What validated rating scales are used in BHI?

Common validated rating scales used in BHI include the PHQ-9 (depression), GAD-7 (anxiety), AUDIT (alcohol use), DAST (drug use), PCL-5 (PTSD), and Mood Disorder Questionnaire (bipolar). The specific scale used depends on the condition being treated.

What is measurement-based care?

Measurement-based care is the practice of using serial validated rating scale scores to drive treatment decisions. When a patient's scores are not improving by specified benchmarks, treatment intensification is triggered. Measurement-based care is a structural element of BHI required by both general BHI and CoCM.

What is a registry-based population health approach?

A registry is a structured tracking system maintaining records of all BHI-enrolled patients including their rating scale scores over time, treatment adjustments, and progress. The registry enables proactive identification of patients not improving and systematic case review. CoCM requires registry-based population health management.

Can BHI be delivered via telehealth?

Yes. BHI is inherently non-face-to-face work that can be delivered via telephone, video, or other communication technology. The BHCM-patient contact, weekly BHCM-psychiatric consultant caseload review, and other BHI activities can be conducted via telehealth. Medicare's behavioral health telehealth flexibilities permanently expanded access without the geographic and originating site restrictions that historically applied to most telehealth services.

Can BHI be billed in FQHCs and RHCs?

Yes. FQHCs and RHCs can bill BHI services. Unlike Chronic Care Management which is bundled under G0511 in the FQHC/RHC payment methodology, BHI services are billed separately under standard CPT codes (99484, 99492, 99493, 99494) within the FQHC/RHC payment methodology.

Can BHI coexist with CCM in the same month?

Yes. BHI and CCM can be billed for the same beneficiary in the same calendar month. The services capture different but complementary care coordination work — CCM for medical multi-condition coordination and BHI for behavioral health care management.

Can BHI coexist with TCM in the same month?

Yes. BHI and TCM can be billed for the same beneficiary in the same calendar month. TCM captures the 30-day post-discharge bridge services while BHI captures the ongoing behavioral health care management.

Can BHI coexist with PCM in the same month?

Yes. BHI and PCM can be billed for the same beneficiary in the same calendar month. PCM captures specialist single-condition disease management while BHI captures the behavioral health integration work.

Can BHI coexist with AWV in the same month?

Yes. BHI and AWV can be billed for the same beneficiary in the same calendar month. The AWV is a single annual visit while BHI is an ongoing monthly service.

What is the IMPACT study and why does it matter for CoCM?

The IMPACT (Improving Mood-Promoting Access to Collaborative Treatment) study was a multi-site randomized controlled trial conducted between 1999 and 2003 by the University of Washington AIMS Center demonstrating that the Collaborative Care Model produced substantially superior outcomes for late-life depression compared to usual primary care. The IMPACT study and subsequent RCTs established CoCM as the most evidence-based behavioral health integration model and provided the foundation for CMS's establishment of the CoCM payment codes in 2017.

Who recognizes CoCM as the leading behavioral health integration model?

SAMHSA (Substance Abuse and Mental Health Services Administration), the American Psychiatric Association (APA), and the AIMS Center at the University of Washington all recognize CoCM as the most evidence-based model for integrating behavioral health into primary care.

What major Georgia health systems deliver BHI?

Major Georgia BHI delivery systems include Emory Healthcare, Wellstar Health System, Piedmont Healthcare, Augusta University Health, Atrium Health Navicent, Memorial Health, Phoebe Putney Health System, Northeast Georgia Health System, the Georgia FQHC network, and the Georgia RHC network. Emory and Augusta University as academic medical centers operate high-fidelity CoCM programs leveraging their psychiatry departments for psychiatric consultant resources.

How does BHI help with the rural Georgia behavioral health access gap?

BHI — particularly telehealth-delivered CoCM — represents a critical access pathway for rural Georgia where approximately three-quarters of counties are designated as Mental Health Health Professional Shortage Areas. Telehealth-based CoCM enables rural primary care practices to access metropolitan-area BHCM and psychiatric consultant resources without requiring on-site behavioral health workforce.

Does BHI replace outside psychotherapy or psychiatric care?

No. BHI is a care management framework, not a replacement for direct psychotherapy or specialty psychiatric care. Patients who need psychotherapy continue to receive it from behavioral health providers under separate billing. Patients with complex psychiatric conditions warranting direct psychiatric care continue to receive it. BHI specifically captures the care coordination and management work performed by the primary care team integrating behavioral health into the medical care setting.

What is the role of the psychiatric consultant in CoCM?

The psychiatric consultant provides weekly caseload review with the BHCM, reviewing all CoCM-enrolled patients in the registry, identifying patients not progressing, and making recommendations for treatment adjustments (medication changes, brief intervention adjustments, referral to specialty psychiatric care when warranted). The psychiatric consultant typically does NOT directly evaluate patients in person — the consultation is registry-based and BHCM-mediated.

What evidence-based brief interventions does the BHCM deliver?

Common evidence-based brief interventions delivered by the BHCM include behavioral activation (for depression), problem-solving therapy (PST), cognitive behavioral techniques, motivational interviewing (for substance use and treatment engagement), and relapse prevention planning. These are brief, focused interventions delivered in the primary care setting rather than full courses of formal psychotherapy.

How long do BHI services continue?

BHI services continue as long as clinically appropriate based on the beneficiary's behavioral health care management needs. Patients who achieve remission and stable functioning may be transitioned out of active BHI care management with relapse prevention planning. Patients with chronic or recurrent conditions may continue BHI services indefinitely.

CTA: Contacts for Georgia Medicare BHI Resources

Federal Medicare resources

• Medicare — 1-800-MEDICARE (1-800-633-4227), TTY 1-877-486-2048
• Palmetto GBA (Georgia Medicare Administrative Contractor) — 1-866-238-9650
• SAMHSA National Helpline — 1-800-662-4357 (24/7, free, confidential, English/Spanish)
• 988 Suicide and Crisis Lifeline — Dial 988 (24/7, free, confidential)
• AIMS Center at the University of Washington — Leading research and implementation resource for the Collaborative Care Model

Georgia state behavioral health resources

• Georgia DBHDD (Department of Behavioral Health and Developmental Disabilities)
• Georgia Crisis and Access Line — 1-800-715-4225 (24/7 crisis line, behavioral health services access)
• Georgia Department of Community Health (DCH) Medicaid Member Services — 1-866-211-0950
• GeorgiaCares SHIP — 1-866-552-4464 (Medicare counseling)
• Georgia Department of Public Health (DPH) — 404-657-2700
• Acentra Health (Georgia QIO) — 1-844-455-8708

Advocacy and consumer assistance

• Medicare Rights Center — 1-800-333-4114
• Atlanta Legal Aid Society — 404-377-0701
• Georgia Legal Services Program — 1-800-498-9469
• 211 Georgia — Dial 211 (community resource referral)
• Eldercare Locator — 1-800-677-1116
• NAMI Georgia (National Alliance on Mental Illness) — Local NAMI affiliates across Georgia
• Mental Health America of Georgia

Social Security

• Social Security Administration — 1-800-772-1213

Conclusion: Why BHI Coverage Matters for Every Georgia Medicare Beneficiary

The Medicare Behavioral Health Integration benefit is the federal payment innovation that finally created a sustainable financial framework for integrating evidence-based behavioral health care management into the primary care setting where most older Medicare beneficiaries with behavioral health conditions receive their care. The Collaborative Care Model — rooted in the IMPACT study, recognized by SAMHSA and the APA as the leading behavioral health integration model, and now supported by dedicated Medicare CPT codes — represents the most substantial advance in primary care behavioral health integration of the past three decades. The general BHI framework (CPT 99484) provides a more accessible pathway for primary care practices that cannot operate full CoCM programs but want to bill for behavioral health care coordination work.

For Georgia Medicare beneficiaries, the BHI benefit operates within a state landscape with profound behavioral health workforce gaps, particularly in rural counties. Telehealth-delivered BHI — particularly telehealth-based CoCM with metropolitan-area BHCM and psychiatric consultant resources serving rural primary care practices — represents the most important access pathway for closing rural behavioral health gaps. The Major Georgia health systems delivering BHI (Emory, Wellstar, Piedmont, Augusta University, Atrium Health Navicent, Memorial Health, Phoebe Putney, Northeast Georgia, and the FQHC/RHC networks) collectively provide substantial BHI delivery capacity across the state.

The BHI framework structurally complements the broader Medicare care management coordination framework spanning Chronic Care Management (CCM) for multi-condition coordination, Transitional Care Management (TCM) for post-discharge bridge services, Principal Care Management (PCM) for specialist single-condition management, and the Annual Wellness Visit (AWV) for annual preventive coordination. For multi-morbid older Medicare beneficiaries with comorbid medical and behavioral health conditions — a population characteristic of much of the Georgia Medicare beneficiary base — the appropriate combination of BHI plus other care management benefits supports comprehensive coordination across the full medical and behavioral health spectrum.

Every Georgia Medicare beneficiary with a behavioral health condition requiring care management deserves access to evidence-based behavioral health integration in their primary care setting. The BHI benefit makes this access financially sustainable for primary care practices. The work of disseminating BHI further across Georgia primary care — particularly in rural counties and FQHC/RHC settings serving the medically underserved — is one of the most consequential opportunities in Georgia Medicare policy for closing the behavioral health access gap and improving outcomes for the older Georgians who depend on the primary care system for the integration of medical and behavioral health care.