The Centers for Medicare and Medicaid Services (CMS) is proposing key changes to the 2026 Medicare Physician Fee Schedule that could significantly increase the profitability of Advanced Primary Care Management (APCM), especially for practices offering behavioral health support. For the first time, new optional G-codes will allow practices to bill for Behavioral Health Integration (BHI) or Collaborative Care Model (CoCM) services in the same month as APCM. This proposed shift in billing and reimbursement offers to unlock previously untapped revenue for healthcare providers, making it a pivotal change in the future of care delivery.
Why This Matters
Up until now, most practices don’t usually offer BHI because similar services can be billed at higher rates under Chronic Care Management (CCM). With the new CMS proposal, this won’t be the case any longer. In 2026, APCM participants will be able to bill for both APCM and BHI/CoCM services simultaneously. This change not only allows you to expand care delivery for your patients but also increases reimbursement potential for your practice.
What the New G-Codes Do
CMS is proposing new G-codes, GPCM1, GPCM2, and GPCM3, that mirror existing BHI and CoCM CPT codes but with less administrative complexity. Here’s what makes these new G-codes a significant win for providers:
| Feature | Current Rule | With Proposed G-Codes |
|---|---|---|
| No time-tracking requirements | BHI and CoCM CPT codes (e.g., 99484, 99492) require a minimum number of minutes (20, 60, or 70) of care team time per month to qualify for billing. | Reimbursement will now be based on the service provided, moving away from time-based billing. This reduces documentation burden, simplifies billing, and encourages broader adoption. |
| Allows dual billing with APCM | If you bill for APCM, you generally can’t bill separately for BHI or CoCM in the same month, even if both are provided. | Practices can bill for both BHI/CoCM and APCM in the same month, allowing for reimbursement of both services without having to choose one over the other. |
A Quick Look at the Current CPT Codes
Here’s a breakdown of the existing CPT codes that the new G-codes are modeled after:
| CPT Code | Description | Time Requirement |
|---|---|---|
| 99484 | General BHI care management | ≥20 min/month |
| 99492 | Initial CoCM month | 70 min |
| 99493 | Subsequent CoCM month/s | 60 min |
| 99494 | Add-on (each additional 30 min) | +30 min |
| G0512 | FQHC/RHC CoCM (with G0511) | 30 min |
These codes support behavioral care coordination delivered by clinical staff under the supervision of a physician or a qualified healthcare professional. With the proposed G-codes, practices can bill more efficiently by removing strict time tracking and bundling requirements.
How This Impacts Your Practice
- Increased reimbursement opportunities – Practices can now bill for behavioral and primary care services simultaneously under APCM.
- Reduced administrative burden – The new G-codes are not time-based, making documentation and billing easier.
- Expanded care offerings – You can offer meaningful behavioral health support without sacrificing revenue or adding billing complexity.
Next Steps for Providers
If you’re enrolled in APCM or leaning towards it, here are a few things to consider next:
- Evaluate your care workflows – Do they include behavioral health support that could qualify for BHI/CoCM billing?
- Plan for 2026 integration – Anticipate how these changes could improve patient care and your bottom line.
- Align with the 13 APCM elements – Our model at RPM Logix already checks all the boxes. See how we do it in this article.
Want to learn more?
RPM Logix offers a complete outsourced solution for a dual APCM / BHI Program.
- To be eligible to bill APCM codes, you must meet all of the 13 required service elements.
RPM Logix’s platform meets all the required service elements, including the most challenging ones, which involve Population Health and Care Gap reporting.
- Our Care Team, featuring nurses, registered dietitians, and certified diabetes educators, can extend your APCM program to provide BHI services. This could amount to over $150 in combined reimbursement per patient each month.
📞 Interested? Schedule a strategy call or fill out the form below to get started with a demo.