As the U.S. healthcare system continues its shift toward comprehensive, whole‑person care, the Centers for Medicare & Medicaid Services (CMS) is expanding payment models to better support integrated primary and behavioral health services. In 2026, CMS introduced new behavioral health integration (BHI) and psychiatric collaborative care management (CoCM) add‑on codes designed to strengthen the Advanced Primary Care Management (APCM) model launched in 2025.
This month’s FWA Insights highlights what special investigation units (SIUs) should know about the new add‑on codes, how they differ from previous requirements, and the potential vulnerabilities to errors, upcoding, and fraud that health plans may encounter as providers adapt to the updated billing structure.
Background: CMS rolls out APCM
In 2025, CMS implemented Advanced Primary Care Management (APCM) as a new care‑management program aimed at supporting primary care teams treating patients with chronic and complex conditions. APCM was built on a monthly care‑coordination framework and required providers to furnish 13 service elements tailored to individual patient needs. The program marked a strategic move away from visit‑based billing toward ongoing longitudinal care.
These new codes shift reimbursement from rigid, time-based documentation to more flexible, team-based care. The looser documentation requirements and expanded provider eligibility create a high potential for billing errors, upcoding, and fraud that health plan SIU teams need to be aware of.
New APCM code details
APCM base codes established in 2025
CMS created three monthly APCM base codes—HCPCS G0556 through G0558—to support ongoing care coordination for patients with varying levels of clinical complexity.
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G0556: Services for patients with one or no chronic conditions
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G0557: Services for patients with two or more chronic conditions lasting ≥12 months and posing significant risk
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G0558: Services for Qualified Medicare Beneficiary patients meeting the same chronic‑condition criteria as G0557
Unlike traditional visit‑based billing, APCM codes represent a monthly, patient‑centered approach designed to support long‑term, relationship‑based care rather than a bill per visit. These codes reimburse care teams for monthly management activities like ongoing care coordination, chronic condition management, including transitional care, medication management, and addressing medical and social determinants of health.
New 2026 add‑on codes for BHI and CoCM services
In 2026, CMS expanded the APCM model and launched three new add‑on HCPCS codes—G0568 through G0570—based on patient risk and care intensity. The intent is for these codes to be used in conjunction with the APCM base codes when behavioral health integration and psychiatric collaborative care management services are rendered by physicians, practitioners, rural health clinics (RHCs), and federally qualified health centers (FQHCs).
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G0568: Initial/first month of psychiatric collaborative care management
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G0569: Subsequent months of psychiatric collaborative care management
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G0570: General behavioral health integration services
These codes cross‑walk to CPT codes 99492–99494, but importantly, CMS has removed the time‑based requirements previously attached to those CPT codes. Instead, billing is tied to services rendered, reducing administrative burden and allowing teams to focus on care complexity rather than time thresholds.
This update represents a significant shift from previous requirements for RHCs and federally qualified health centers, which historically reported CoCM using the bundled HCPCS code G0512 with CPT codes 99492–99494. As of 2026, G0512 has been deleted, and RHCs/FQHCs must now bill using the corresponding CPT/HCPCS codes that reflect the specific behavioral health service delivered. This change is intended to improve transparency, accuracy, and alignment of behavioral health billing across care settings.
Moving forward
There are several key areas of potential FWA vulnerability that stakeholders should closely monitor, with the most pressing including:
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Standalone or incorrect billing of add‑on codes: Because the new BHI and CoCM add‑on codes were previously part of a single bundled service, there is heightened risk that they may be billed as standalone services. Health plans should confirm that G0568–G0570 are submitted only alongside an appropriate APCM base code and that both the base and add‑on codes are billed once per month, by the same rendering provider, with patient consent properly documented.
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Unbundling and duplicate billing risks: APCM codes are intended to reflect a comprehensive, monthly approach to care. As such, they should not be billed in conjunction with other care‑management programs—such as Transitional Care Management (TCM) or Chronic Care Management (CCM)—in the same service period. Doing so constitutes unbundling and may result in duplicative or inappropriate payment.
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Missing or incomplete care‑team structure: BHI and CoCM services rely on coordinated, team‑based care involving the treating practitioner, a behavioral health care manager, and a psychiatric consultant. Claims submitted without evidence of this required multidisciplinary team represent a significant vulnerability and warrant further review.
As CMS continues refining the APCM model, the introduction of new behavioral health add‑on codes represents a meaningful step toward more integrated, patient‑centered care. By eliminating outdated time‑based requirements and replacing bundled billing with more precise coding, CMS aims to better reflect the true complexity of both behavioral and chronic condition management.
For SIU teams, these changes create an important opportunity to strengthen oversight, ensure accurate reporting, and support providers in delivering coordinated care that truly addresses patients’ whole‑person needs. At the same time, the looser documentation requirements create potential for billing errors, upcoding, and fraud that SIU teams need to continually monitor.
Webinar: Navigating regulatory changes and FWA schemes in 2026
Dive deeper and stay ahead of potential FWA patterns. Don’t miss our latest on-demand Payment Integrity Pulse webinar as we discuss key regulatory changes and the trending schemes found in Cotiviti data that may be affected by these actions.
