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The practical 2026 guide to device rules, day thresholds, management time, and audit defensibility for Remote Patient Monitoring.
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CY 2026 Medicare Physician Fee Schedule Final Rule
The APCM Behavioral Health Add-On Rule (2026): Why Same-Month, Same-Practitioner Is Not Optional
CMS tied three new APCM behavioral health integration add-ons—G0568 (CoCM initial month), G0569 (CoCM subsequent months), and G0570 (general BHI)—to APCM starting January 1, 2026. If the APCM billing practitioner and the add-on billing practitioner diverge—even once—you create denial and audit risk.
How to use this page: Operationalize it. Treat the attachment rule as part of your system constraints--not a guideline. This is not legal advice.
Rule Snapshot
Add-On Codes
G0568, G0569, G0570
Effective Date
January 1, 2026
Audience
Practice owners, medical directors, billing/RCM leaders, compliance officers, care-management operators
Last Updated
December 18, 2025
Overview
CMS finalized three new APCM behavioral health add-on codes for 2026 that may be billed only when the APCM base code is billed by the same practitioner in the same month. CMS also updated Medicare Shared Savings Program (MSSP) beneficiary assignment rules so these integrated services, when furnished with APCM, are treated as primary care services for assignment.
If your systems cannot tie eligibility, attribution, month-level ownership, and documentation artifacts into one narrative, you are building denial and audit risk into your 2026 operations.
Operationally, these aren’t “generic behavioral health work” codes. Two codes (G0568/G0569) represent Psychiatric Collaborative Care Management (CoCM) delivered through a team-based model (treating practitioner + behavioral health care manager + psychiatric consultant). The third (G0570) represents general Behavioral Health Integration (BHI), which may be staffed without a psychiatric consultant but still must be directed and owned by the APCM billing practitioner for that patient-month.
Section Index
- Key Takeaway in One Sentence
- The Core Rule (what CMS actually finalized)
- What APCM requires each month (the dependency you cannot ignore)
- Common failure patterns (how practices will get this wrong)
- Why those patterns are non-compliant (auditor logic)
- Edge cases and clarifications
- Forward-looking CMS trajectory (why this is bigger than coding)
- Practical implications for practices
- Planning checklist
- How FairPath enforces this
- FAQ
- References
1. Key Takeaway in One Sentence
G0568, G0569, and G0570 can only be billed as APCM add-ons when the APCM base code is billed by the same practitioner for the same patient in the same calendar month—anything that breaks that attachment breaks the service definition and creates denial/audit risk. ([CMS])
2. The core rule explanation
2.1 What CMS finalized (the add-ons)
CMS finalized the establishment of three new G-codes to be billed as add-on services when the APCM base code is reported by the same practitioner in the same month. ([CMS]) Those codes are G0568, G0569, and G0570, and CMS describes them as directly comparable to existing CoCM and general BHI codes. ([CMS])
2.2 The billing conditions are not guidance—they are definitional
Same-month, same-practitioner is the condition under which the add-on exists as a payable service. The operational question is: did the billing practitioner who billed APCM also furnish/bill the add-on in that same calendar month, and can you prove it in the medical record? ([CMS])
2.3 What each add-on code represents (and what you must be able to defend)
CMS describes these add-ons as comparable to established CoCM and general BHI services. Treat that as a clinical-model constraint: if you bill a CoCM add-on, your records should reflect a CoCM team model; if you bill the general BHI add-on, your records should reflect ongoing integrated behavioral health care management under the treating practitioner’s direction.
| HCPCS | Model shorthand | When you use it | Minimum team reality | What auditors expect to see (examples) |
|---|---|---|---|---|
| G0568 | CoCM (initial month) | Starting a new CoCM episode | Treating practitioner + BH care manager + psychiatric consultant | Initiating touchpoint/visit + consent; baseline assessment using validated scales; registry/caseload entry; initial behavioral care plan; psychiatric consultant review + recommendations; treating practitioner oversight and plan action |
| G0569 | CoCM (subsequent months) | Continuing that CoCM episode in later months | Treating practitioner + BH care manager + psychiatric consultant | Ongoing follow-up + symptom tracking; registry maintenance; periodic psychiatric consultant caseload review; plan adjustments; treating practitioner action/oversight documented within the APCM month narrative |
| G0570 | General BHI | Integrated BH care management without full CoCM infrastructure | Treating practitioner + clinical staff/care manager (psychiatric consultant not required) | Care plan linkage; BH monitoring and care coordination; brief interventions/coaching within scope; coordination with external BH providers where applicable; evidence the treating practitioner directs and integrates the BH plan into longitudinal care |
Practical coding constraint: pick a single “behavioral integration pathway” per patient-month. If your documentation reads like CoCM but you bill general BHI (or vice versa), you have created a mismatch that is easy to deny.
3. APCM base code dependency: what must be true before the add-on can exist
Because these are add-ons, the APCM month must be valid. CMS makes several constraints explicit that directly impact the add-ons. ([CMS])
- APCM is billed once per patient per calendar month.
- Consent must be obtained and documented, informing the patient that only one provider can furnish and be paid for APCM during a calendar month.
- APCM requires a longitudinal operating model (24/7 access, continuity, care plan maintenance, transitions coordination, population-level management).
3.1 Treating practitioner vs. behavioral health team roles (why “same practitioner” is the point)
In BHI/CoCM models, Medicare’s structure is intentionally practitioner-centric: the treating practitioner is the accountable clinical owner who directs the integrated behavioral health work and bills for it. Behavioral health team members contribute under that ownership model; they don’t replace it.
- Treating practitioner (billing professional): initiates/directs integration, owns the longitudinal care plan, receives and acts on recommendations, and must be the same practitioner who bills APCM for the patient-month.
- Behavioral health care manager: conducts assessments, maintains the behavioral health care plan, performs follow-ups and brief interventions within scope, tracks outcomes (often via validated scales), and coordinates care under the treating practitioner’s direction.
- Psychiatric consultant (CoCM only): reviews the care manager’s caseload and provides treatment recommendations that the treating practitioner implements/oversees; typically does not see the patient directly as part of the CoCM infrastructure.
This is why the add-on can’t “float” to whichever clinician is closest to the behavioral health workflow. The month-owner is the accountable owner.
3.2 Preconditions you should treat as hard gates (consent + initiating touchpoint)
- APCM consent: document consent and the disclosure that only one provider can furnish and be paid for APCM in a calendar month. Make consent capture deterministic and retrievable.
- BHI/CoCM consent: obtain and document beneficiary consent for behavioral health integration services (including cost-sharing disclosure where applicable). Keep it auditable.
- Initiating touchpoint: for BHI/CoCM workflows, build an “initiating” step into your operational model (especially for new patients or those not recently seen) so you can defend that integration was established under the treating practitioner’s care relationship.
If consent and initiating steps are implicit, you will lose months on appeal because you cannot prove the service definition was satisfied—even if “work happened.”
If behavioral health add-ons are attached to a month where APCM requirements were not met or ownership is ambiguous, the add-on is the easiest element for an auditor to challenge.
4. Common failure patterns and traps
Trap 1: Split-practitioner billing inside one group
Scenario: Dr. A bills APCM for the month, but behavioral health work is documented or billed under Dr. B, and the practice attempts to bill the add-on under Dr. B. This fails because the add-on must be billed when the APCM base code is billed by the same practitioner in the same month. ([CMS])
Trap 2: Cross-month “floating” to make the paperwork work
Scenario: Behavioral health activity happens late in Month 1, APCM is billed in Month 2, and the team tries to move the add-on to Month 2. APCM is a calendar-month unit and the add-on is tied to the same month. ([CMS])
Trap 3: Vendor-run behavioral health integration with no practitioner-level ownership trail
Scenario: A third party runs screening, follow-ups, coaching, or care-manager contacts, and the practice wants to bill the add-on because the work happened. The add-on is part of a practitioner-owned APCM month; the record must show the APCM billing practitioner is the accountable owner. ([CMS])
Trap 4: Missing longitudinal plan linkage
Scenario: Behavioral health notes exist but are not linked to the APCM care plan or the month-level APCM note. APCM requires maintaining and updating an electronic, patient-centered comprehensive care plan accessible to the care team. If the add-on is billed as integrated but the record shows silos, you have created an “integration claim without integration evidence.” ([CMS])
Trap 5: Billing CoCM add-ons without CoCM infrastructure
Scenario: The practice bills G0568/G0569 but cannot show psychiatric consultant involvement, caseload review, or a care-manager-led CoCM workflow. If the record reads like “general BHI” but the claim reads like CoCM, you’ve created an internal contradiction that is straightforward to deny.
Trap 6: Using the “initial month” code as a recurring monthly code
Scenario: The practice repeatedly bills G0568 month after month because it “pays better” or because the team didn’t implement CoCM episode state (initial vs subsequent months). This is a predictable audit target: the code itself is intended to represent an initial-month construct, so repeated “initial month” billing needs a defensible clinical and operational explanation.
5. Why these patterns are non-compliant (auditor logic)
- The add-on is defined as an add-on. CMS states it is billed only when APCM is billed by the same practitioner in the same month. ([CMS])
- APCM is a monthly unit with exclusive ownership; consent language requires informing the patient that only one provider can be paid for APCM in a month. ([CMS])
- CMS treats these integrated add-ons as primary care services for MSSP assignment when furnished with APCM, signaling they define primary care ownership. ([CMS])
- Program integrity pressure is real for longitudinal billing categories; OIG has documented overpayments in CCM and called for RPM oversight, so integrated add-ons are easy targets if attachment is weak. ([Office of Inspector General])
“We did the work” is not a defense. The defensible position is: the service definition was met, the attachment rule was met, and the month-level narrative is internally consistent.
6. Edge cases and clarifications
“Same practitioner” -- operational meaning
Treat “same practitioner” as the same billing professional (NPI) who billed the APCM base code also billing the add-on for that patient-month. Design workflows assuming this is practitioner-specific, not group/TIN-level. ([CMS])
Patient changes clinicians mid-month
APCM is billed once per calendar month and consent language contemplates one provider being paid for APCM in the month. You need a deterministic rule for who owns the month (and therefore whether the add-on can be billed), and documentation must support that ownership. ([CMS])
Auxiliary staff and incident-to
CMS allows auxiliary personnel to support APCM (and comparable care-management services) under incident-to rules with general supervision. “Auxiliary personnel” is broader than employees—it can include leased staff or independent contractors—so vendor-supported models can be workable if they’re structured so the personnel function as auxiliary personnel under the billing practitioner’s direction and control. The compliance burden is proving the structure: written agreements, supervision and escalation pathways, documentation integration, and a clear trail tying the work to the APCM month-owner. ([CMS])
RHC/FQHC operational pitfall: composite code transitions
For FQHCs/RHCs, APCM behavioral health add-ons G0568–G0570 can support BHI/CoCM billing with APCM, and consolidated codes like G0512 and G0071 are no longer reportable beginning January 1, 2026, requiring reporting of the individual component codes. ([CMS])
6.5 Contracting and compensation: what is structurally high-risk
Because the billing practitioner is paid for integration services that are often performed by care managers and consultants, the business arrangement matters. This page is not legal advice, but it is an operational warning: structures that look like paying for referrals (rather than paying for bona fide services) are where programs get hurt.
- Low-friction structures (typical): W-2 employment for a BH care manager, or a fixed-fee services agreement (flat monthly or hourly rate) for contracted care manager / psychiatric consultant services.
- High-risk patterns to avoid: percentage-of-collections splits, per-referral “bounties,” free/underpriced staff provided in exchange for referrals, and side deals that do not reflect fair market value for actual services.
- Operational proof point: if asked “why is this compensation amount what it is,” you should be able to answer without referencing expected Medicare collections.
Where virtual direct supervision fits
This rule is about attachment, not supervision. For services requiring direct supervision, CMS permanently allows real-time audio-video to meet direct supervision requirements where applicable. Treat this as a narrow compliance mechanism, not permission to change who is doing the work. ([CMS])
7. Forward-looking policy context: why CMS is doing this
CMS revised the MSSP primary care services definition to include the new behavioral health integration and psychiatric collaborative care add-on services when furnished with APCM starting performance year January 1, 2026. That means CMS uses integrated APCM + behavioral health to define primary care for attribution, reinforcing longitudinal ownership rather than modular billing. ([CMS])
8. Practical implications for practices
- Pick a month-owner and make it unambiguous. APCM is billed once per calendar month and only one provider can be paid for the month. ([CMS])
- Embed behavioral health integration inside the APCM month artifact. The record must tie behavioral health work to the longitudinal care plan APCM requires. ([CMS])
- Validate attachment before you create claims. Block add-on claims without a valid APCM month or where the billing practitioner does not match. ([CMS])
9. Planning checklist
- Define the APCM month owner rule and enforce it through policy and system constraints. ([CMS])
- Capture APCM consent once with the “only one provider per month” disclosure. ([CMS])
- Add month-level validation that the add-on is billed only when APCM is billed by the same practitioner that month. ([CMS])
- Link behavioral health integration documentation to the APCM care plan update. ([CMS])
- For MSSP participants, treat these add-ons with APCM as assignment-relevant primary care services and ensure the billing narrative supports attribution. ([CMS])
- For RHC/FQHCs, implement code transitions (e.g., G0512/G0071 reporting changes) before January 1, 2026. ([CMS])
10. How FairPath enforces this
- Eligibility gate: No add-on claim exists unless the APCM month is valid (consent present, month-owner established, APCM requirements satisfied). ([CMS])
- Attachment rule: Enforce same patient, same calendar month, same billing practitioner for the add-on. ([CMS])
- Model integrity: Validate CoCM vs general BHI pathway selection (e.g., don’t allow CoCM add-ons without evidence of a CoCM team model and consultant review cadence).
- Incident-to defensibility: If auxiliary personnel are contracted, require evidence of a compliant structure (agreement, supervision/escalation workflow, documentation integration) before treating the month as claimable.
- Attribution coherence: For MSSP participants, flag conflicts where the billing narrative would undermine assignment logic. ([CMS])
- Audit trail readiness: Produce a month-level evidence packet (APCM month note, care plan update, behavioral health artifacts, claim metadata).
11. FAQ
1
Are G0568/G0569/G0570 optional?
Yes—the add-ons are optional. But if you bill them, the attachment requirements are mandatory. ([CMS])
2
Can we bill an add-on without billing APCM that month?
No. CMS defines them as add-on services billed when the APCM base code is reported by the same practitioner in the same month. ([CMS])
3
What do G0568, G0569, and G0570 actually represent?
They represent specific behavioral health integration models inside APCM: G0568 = CoCM initial month, G0569 = CoCM subsequent months, and G0570 = general BHI. Treat them as model-specific add-ons, not generic “behavioral work.”
4
Do CoCM add-ons require a psychiatric consultant?
If you bill the CoCM pathway (G0568/G0569), your operations and records should reflect a CoCM team model, including psychiatric consultant input and care-manager-led follow-up. If you don’t have that infrastructure, general BHI (G0570) is the more defensible model construct.
5
Can the behavioral health care manager or psychiatric consultant be contracted (not employed)?
Often yes, but structure matters: the personnel must operate as part of the treating practitioner’s care team under incident-to expectations (direction/control, supervision workflow, documentation integration). Contracting does not change the same-month, same-practitioner attachment rule.
6
Can one clinician bill APCM and a different clinician bill the add-on in the same month?
CMS’s finalized condition is “same practitioner” and “same month.” Design your workflow assuming the answer is no. ([CMS])
7
Does “same practitioner” mean the same group/TIN?
Treat it as the same billing professional who reports the APCM base code for that patient-month. ([CMS])
8
What if the behavioral health work is performed by care managers or other staff?
Staff involvement does not change the billing condition. APCM has explicit incident-to and auxiliary personnel rules; documentation must still support the APCM month-owner and the add-on attachment. ([CMS])
9
If we already bill Collaborative Care (CoCM) today, can we just “switch to the add-on” when we start APCM?
Do not assume “same workflow, same billing.” The add-ons are comparable to CoCM/BHI codes but are defined as APCM add-ons with explicit attachment conditions. ([CMS])
10
If we bill APCM, does that automatically qualify us to bill the add-ons?
No. The add-ons are optional and require furnishing and documenting behavioral health integration with APCM. APCM validity is necessary but not sufficient. ([CMS])
11
Does this affect Medicare Shared Savings Program (ACO) assignment?
Yes. CMS includes these add-on services when furnished with APCM in the primary care services definition for MSSP assignment starting 2026. ([CMS])
12
What’s the most common operational mistake you expect in 2026?
Split-practitioner reality (behavioral health under one clinician, APCM under another) collides with the same-practitioner requirement. ([CMS])
13
If a patient changes PCP mid-month, can both clinicians bill APCM and/or the add-on?
APCM is billed once per patient per calendar month and consent requires disclosing that only one provider can be paid for APCM in a month. Prevent dual billing. ([CMS])
14
How should we document “integration” so it’s defensible?
At minimum: the APCM month note should show behavioral health integration as part of the longitudinal plan and link behavioral health work to the APCM care plan update. ([CMS])
15
We’re an RHC/FQHC--anything special?
CMS notes that consolidated codes like G0512/G0071 are no longer reportable beginning January 1, 2026, requiring reporting of underlying codes. Enforce same practitioner/month attachment alongside those transitions. ([CMS])
16
Is this primarily a “billing rule” or a “clinical operations rule”?
Both. CMS made it a billing condition and reinforced the clinical-policy intent by incorporating these integrated add-ons (when furnished with APCM) into the MSSP primary care services definition. ([CMS])
17
How does this relate to audit risk?
Longitudinal, non-face-to-face billing categories have documented program integrity attention (e.g., OIG findings on CCM overpayments and calls for RPM oversight). Weak attachment or attribution controls make these add-ons easy targets. ([Office of Inspector General])
12. References
Primary sources (CMS / government):
- CMS: CY 2026 Medicare Physician Fee Schedule Final Rule Fact Sheet (CMS-1832-F) (add-ons billed by same practitioner in same month). ([CMS])
- CMS: MM14315 / MPFS Final Rule Summary (CY 2026) (add-ons billed when APCM base is billed by same practitioner; comparable to CoCM/BHI). ([CMS])
- CMS: CY 2026 PFS Final Rule – MSSP changes fact sheet (includes add-ons with APCM in the primary care services definition for assignment). ([CMS])
- CMS: Advanced Primary Care Management Services page (once per month, consent language, care plan requirements, auxiliary personnel rules). ([CMS])
- CMS: MLN Booklet — Behavioral Health Integration Services (roles, consent, initiating visit, general supervision, service model expectations). ([CMS])
- CMS: Behavioral Health Integration (BHI) FAQs (care manager/psychiatric consultant may be employees or under contract; operational clarifications). ([CMS])
- eCFR: 42 CFR §410.26 (incident-to; auxiliary personnel definitions and supervision concepts). ([eCFR])
- Federal Register: OIG Compliance Program Guidance for Individual and Small Group Physician Practices (FMV and referral-risk patterns). ([OIG])
- OIG: Medicare continues to make overpayments for Chronic Care Management (program integrity context). ([Office of Inspector General])
- OIG: Additional oversight of Remote Patient Monitoring in Medicare is needed (program integrity context). ([Office of Inspector General])
- CMS: Federally Qualified Health Centers (FQHC) Center (code transition notes). ([CMS])
Secondary sources: None required; the above CMS/OIG materials anchor this article.
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