If your practice already bills Advanced Primary Care Management, the January 1, 2026 behavioral health add-ons are the cleanest way to get paid for Collaborative Care Model or general BHI work in the same calendar month. The rule is simple on paper and easy to break in the claim scrubber: report an APCM base code (G0556, G0557, or G0558) and the matching add-on (G0568, G0569, or G0570) under the same practitioner in the same month. The add-ons are not time-based. They still require a real CoCM or general BHI program, not a checkbox.

This guide walks through who can use the pathway, how the three add-ons map to existing CoCM and BHI services, the documentation that survives review, the mistakes that trigger denials eight months into 2026, and what the CY 2027 proposed rule (comments due September 14, 2026) would change about valuation.

Background: why CMS built APCM, then layered behavioral health on top

CMS created Advanced Primary Care Management for dates of service on or after January 1, 2025. The idea was to pay a monthly bundle for the work of being the patient’s primary care home without forcing staff to stop every fifteen minutes and log care-management minutes. Per the CMS Advanced Primary Care Management Services page, APCM folds together elements of principal care management, transitional care management, chronic care management, and several communication technology-based services into one monthly code family.

The three base codes sort patients by medical and social complexity:

• G0556 (Level 1): clinical staff furnish APCM under a physician or other qualified health care professional who is responsible for all primary care and serves as the continuing focal point for needed health care services. Typically used when the patient has zero or one chronic condition.
• G0557 (Level 2): patient has two or more chronic conditions expected to last at least 12 months (or until death) that place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline, plus all G0556 requirements.
• G0558 (Level 3): same clinical complexity as G0557, and the patient is a Qualified Medicare Beneficiary.

APCM is billed once per patient per calendar month. It is not a minute-counter. You still must be able to deliver the APCM service elements when they are clinically appropriate (consent, initiating visit rules for new patients, 24/7 access and continuity, comprehensive care management, an electronic patient-centered care plan, care-transition coordination, home- and community-based coordination, enhanced communication options, population-level management, and performance measurement). You do not have to furnish every element every month. You do have to be able to furnish them.

What APCM did not originally include was a clean, non-time-based way to recognize psychiatric Collaborative Care Model (CoCM) or general behavioral health integration (BHI) when those services ride alongside the APCM month. Practices that already ran CoCM kept tracking 70- and 60-minute care-manager thresholds under CPT 99492 / 99493. Practices that ran general BHI kept the 20-minute clinical-staff threshold under CPT 99484 (or HCPCS G0323 for clinical psychologists and clinical social workers). That split documentation burden is exactly what the 2026 add-ons were built to reduce.

CMS finalized the three optional add-ons in the CY 2026 Medicare Physician Fee Schedule. MLN Matters MM14315 (CR 14315) states the policy in one sentence set: the three new HCPCS codes (G0568, G0569, and G0570) are to be billed as add-on services when the APCM base code is reported by the same practitioner in the same month, and they are meant to be directly comparable to existing CoCM and general BHI codes. CMS MLN booklet MLN909432 (Behavioral Health Integration Services, January 2026) updates the operational guidance and is the staff-training source of truth for consent, team roles, initiating visits, and the non-time-based nature of the add-ons.

The 2026 APCM behavioral health add-on code map

Use this map as your chargemaster and claim-edit foundation.

Psychiatric CoCM with APCM

• G0568: psychiatric CoCM services furnished to a patient also receiving APCM in the initial month of the CoCM episode under the APCM pathway.
• G0569: psychiatric CoCM services furnished to a patient also receiving APCM in a subsequent calendar month of the CoCM episode.

CMS MLN909432 groups both codes as the CoCM add-ons for APCM patients. MM14315 and the claims-processing update that accompanied CR 14315 treat them as comparable to the existing CoCM family rather than as brand-new clinical inventions. In practice, G0568 aligns with the clinical work of an initial CoCM month (historically tied to CPT 99492), and G0569 aligns with subsequent-month CoCM work (historically tied to CPT 99493).

General BHI with APCM

• G0570: general BHI services furnished to a patient also receiving APCM in the same calendar month.

G0570 is the APCM-pathway counterpart to general BHI (CPT 99484 / HCPCS G0323), not to CoCM. If your model does not include a psychiatric consultant and a designated behavioral health care manager operating a CoCM registry, do not stretch G0568 or G0569 to fit. Use G0570 when general BHI is what you actually deliver.

What “not time-based” does and does not mean

MLN909432 is explicit: the new HCPCS codes aren’t time-based. That removes the 70 / 60 / 20-minute billing thresholds that make or break standalone CoCM and BHI claims. It does not remove the clinical model. You still need:

• An identified mental, behavioral, or psychiatric condition (including substance use disorder) that requires assessment, care planning, and intervention.
• The right care-team structure for the code you chose.
• Documented patient consent for BHI / CoCM activity.
• Registry, validated rating scales, and psychiatric consultation when you bill CoCM.
• An APCM base code on the claim for that same patient-month.

If your only change was deleting the minute log and leaving the clinical program empty, you do not have a payable add-on. You have an audit target.

The hard rule: same practitioner, same month, same APCM base

Every primary CMS source repeats the pairing requirement. MLN909432: you must meet all requirements and bill an APCM base code (G0556, G0557, or G0558) in the same month as the optional add-on. MM14315: bill the add-on when the APCM base code is reported by the same practitioner in the same month. FQHC and RHC MLN booklets (MLN006397, MLN006398) carry the same pairing language and note that care-coordination services and their associated add-ons are paid at the national non-facility PFS rate in those settings.

Build claim edits around three checks before the claim leaves the practice:

1. Base present. G0568, G0569, or G0570 never travels alone. If APCM was not furnished and billed that month, use the standalone CoCM or BHI codes instead.
2. Same rendering practitioner. The NPI on the APCM line and the add-on line must match. A covering partner who “owns” APCM while a different clinician “owns” CoCM for the month is how you manufacture a denial.
3. Same calendar month. Do not straddle months to force a match. CoCM episodes can span months. Each billed month still needs its own valid APCM base plus the correct initial vs subsequent add-on.

APCM consent also matters here. CMS requires written or verbal consent documented in the record, including notice that only one provider can furnish and be paid for APCM during a calendar month, that the patient may stop services at any time, and that cost sharing may apply. If two practices both think they are the APCM home for the same beneficiary, one of them (and possibly the attached behavioral health add-on) will not be paid.

Who can actually use this pathway

Two different CMS rules get mixed up in specialty billing conversations. Keep them separate.

Who can bill APCM (and therefore the add-ons)

Per the CMS APCM page, the billing physician or NPP (NP, PA, or CNS) must be responsible for all of the patient’s primary care services and must be the focal point for all needed health care services. CMS says the codes are primarily for primary care specialties such as general internal medicine, family medicine, geriatric medicine, or pediatrics. Auxiliary personnel may furnish APCM incident to under general supervision, but the billing practitioner still owns the month.

That is a high bar for many independent specialty clinics. A radiation oncology center, a freestanding urology group, or a medical oncology infusion suite that is not the patient’s primary care home generally should not invent an APCM claim just to unlock G0568. If you are not the focal point for primary care, the add-on is not your pathway. Partner with the primary care practice that is, or bill standalone CoCM / BHI when you meet those rules as the treating practitioner.

Who can be the CoCM treating (billing) practitioner

MLN909432 is clearer and broader for CoCM itself. The treating (billing) practitioner is a physician or NPP who typically works in primary care but may specialize in other fields, such as cardiology or oncology. That sentence matters for medical oncology and other longitudinal specialty practices that run a true CoCM team even when they are not billing APCM. In that case you stay on 99492 / 99493 / 99494 or G2214, not on G0568 / G0569.

Behavioral health practices and FQHCs / RHCs

Independent behavioral health groups usually do not bill APCM as the primary care home. They often serve as the behavioral health care manager vendor or psychiatric consultant under another practice’s CoCM. FQHCs and RHCs can bill APCM base codes and the 2026 add-ons; CMS pays those care-coordination codes and add-ons at the national non-facility PFS rate when reported on the clinic claim. If you bill in an FQHC or RHC, confirm your MAC’s claim-line instructions and do not assume the physician-office workflow ports one-for-one.

CoCM clinical requirements still apply under G0568 and G0569

Removing the minute threshold does not remove the Collaborative Care Model. MLN909432 describes a three-person team:

1. Treating (billing) practitioner: directs care, remains involved through oversight, management, collaboration, and reassessment, and may prescribe and treat medical conditions.
2. Behavioral health care manager: designated clinician with formal education or specialized training in behavioral health (social work, nursing, or psychology), working under the billing practitioner’s direction. Administers validated rating scales, maintains the registry, delivers brief evidence-based psychosocial interventions, and participates in weekly caseload consultation with the psychiatric consultant.
3. Psychiatric consultant: medical provider trained in psychiatry and qualified to prescribe the full range of medications. Regularly reviews caseload status, recommends treatment adjustments, and typically works remotely without routine direct patient contact.

Required CoCM ingredients still include an initial assessment with validated rating scales, joint care planning, registry tracking, weekly caseload review with the psychiatric consultant, and brief interventions such as behavioral activation or motivational interviewing. Under the standalone codes, the first month needs at least 70 minutes of behavioral health care manager time (99492), subsequent months need at least 60 minutes (99493), and each additional 30 minutes uses 99494. G2214 covers a shorter 30-minute CoCM month when you do not meet the longer thresholds. Under G0568 / G0569 you are not proving those minute floors for payment, but you are still proving that CoCM happened.

Episode logic also still matters clinically. MLN909432 says a CoCM episode ends when the patient meets targeted treatment goals, fails to meet them and is referred for direct psychiatric care, or has a break with no CoCM for six consecutive months. Use G0568 for the initial APCM-linked CoCM month of an episode. Use G0569 for later months in that same episode. Restarting G0568 every month because the claim form has a blank is a compliance problem, not a revenue opportunity.

General BHI under G0570: lighter team, still not “anything behavioral”

General BHI is for care models other than CoCM that systematically assess and monitor patients, adjust plans when patients are not improving, and keep a continuous relationship with an appointed care team member. MLN909432 notes you may report general BHI for models that do not involve a psychiatric consultant or behavioral health care manager, although those personnel may still participate.

Standalone general BHI (99484) requires at least 20 minutes of clinical staff time per calendar month under physician or other QHP direction, including assessment or monitoring with validated rating scales when applicable, behavioral health care planning, facilitation and coordination of treatment, and continuity with an appointed care team member. G0323 is the parallel code when a clinical psychologist or clinical social worker personally furnishes at least 20 minutes.

G0570 is the APCM-month version of that general BHI work. It is the right code when:

• The patient is in a valid APCM month under the same practitioner.
• You are delivering general BHI, not full CoCM.
• You are not also reporting psychiatric CoCM codes for that patient in the same month.

MLN909432 is direct on the last point for the standalone world: you may not report general BHI codes in the same month as psychiatric CoCM codes for the same patient. Carry that logic into the APCM add-on world. Do not bill G0570 with G0568 or G0569 for the same patient-month.

Choosing the APCM add-on path vs the standalone time-based path

Think in pathways, not in stacked codes.

Pathway A: APCM + behavioral health add-on

• Patient is attributed to your APCM program for the month.
• Same practitioner bills G0556 / G0557 / G0558 plus G0568, G0569, or G0570.
• You document the CoCM or general BHI model without using the standalone minute thresholds for the add-on payment.
• You do not also bill 99492–99494, G2214, 99484, or G0323 for the same patient for the same month for the same integrated behavioral health work. The add-ons are meant to be directly comparable to those existing codes. Billing both is asking Medicare to pay twice for comparable services.

Pathway B: Standalone CoCM or general BHI (no APCM that month)

• Use 99492 / 99493 / 99494 or G2214 for CoCM, or 99484 / G0323 for general BHI.
• Track the minute thresholds.
• Meet initiating-visit and consent rules in MLN909432.
• This is the usual path for specialty treating practitioners (including oncology) who run CoCM but are not the patient’s APCM primary care home.

Pathway C: APCM only

• Bill G0556 / G0557 / G0558 when APCM requirements are met and no separate CoCM or general BHI program is furnished that month.
• Do not append G0568–G0570 as a habit.

Also remember APCM’s own concurrency limits. CMS states APCM may not be billed concurrently for duplicative services such as CCM, PCM, TCM, interprofessional internet consultation, remote evaluation of patient videos or images, virtual check-ins, or online digital E/M (e-visits). Community Health Integration and Principal Illness Navigation can be billed concurrently when time and effort are not double-counted and medical necessity is met. Do not rebuild a banned CCM claim under an APCM label and then hang a behavioral health add-on on it.

Consent, initiating visits, and the chart stack reviewers actually read

Consent (two layers)

1. APCM consent: written or verbal, documented before APCM starts, with the one-provider-per-month disclosure, stop-at-any-time right, and cost-sharing notice. One consent covers ongoing APCM unless the billing practitioner changes.
2. BHI / CoCM consent: before starting BHI services, the patient must give the billing practitioner permission to consult with relevant specialists, including a psychiatric consultant. Inform the patient that cost sharing applies to face-to-face and non-face-to-face services. Written consent is not required. Verbal consent is allowed. Document it. Get new consent if the billing practitioner changes.

Staff often capture one consent and miss the other. Build both into the enrollment workflow.

Initiating visit

BHI services require an initiating visit that establishes the relationship and assesses the patient before BHI starts. Qualifying examples in MLN909432 include an annual wellness visit, IPPE, comprehensive E/M, or TCM visit. For APCM, new patients need a separately paid initiating visit unless the patient was seen in the practice within the past three years or received another care management service (APCM, CCM, or PCM) within the past year. An AWV can qualify as the APCM initiating visit when the practitioner who will be responsible for APCM performs it.

Documentation that supports G0568 / G0569

Keep a monthly packet that a nurse auditor can follow without a scavenger hunt:

• APCM base justification (level, chronic conditions or QMB status, care-plan pointer, continuity notes).
• Behavioral health diagnosis or working diagnosis being managed.
• Validated rating scale results and dates (PHQ-9, GAD-7, or other clinically appropriate scales).
• Registry entry and follow-up tracking.
• Evidence of weekly caseload consultation with the psychiatric consultant (date, participants, recommendations).
• Brief interventions delivered and medication or referral changes.
• Clear signal that the month is initial (G0568) or subsequent (G0569).

Documentation that supports G0570

• APCM base justification.
• Assessment or monitoring activity, including rating scales when applicable.
• Behavioral health care plan or plan updates for patients who are not progressing.
• Facilitation or coordination of psychotherapy, pharmacotherapy, counseling, or psychiatric consultation.
• Named care team member responsible for continuity.

Supervision

MLN909432 assigns general supervision under the PFS for BHI services the billing practitioner does not personally perform. General supervision means overall direction and control. It does not require physical presence. It also does not, by itself, create the qualifying relationship among care team members. Contracts, role descriptions, and registry ownership still have to show a real team.

Practical month-end workflow for independent practices

Use a closing checklist the last two business days of each month.

1. Pull the APCM roster. Confirm each patient still has documented consent and an assigned billing practitioner.
2. Flag behavioral health enrollees. Separate CoCM registry patients from general BHI patients. No dual assignment for the same month.
3. Confirm team activity. For CoCM, verify weekly psychiatric consultation notes and registry updates. For general BHI, verify assessment or monitoring and care-plan activity.
4. Choose one pathway per patient. APCM + add-on, or standalone timed code, or APCM only.
5. Lock the rendering NPI. The APCM line and add-on line must match before charge entry.
6. Pick the correct add-on. G0568 only for the initial CoCM month on the APCM pathway. G0569 for later CoCM months. G0570 only for general BHI.
7. Hard-edit the claim scrubber. Reject G0568–G0570 without a same-month, same-NPI APCM base. Reject G0570 with G0568/G0569. Reject APCM add-ons with 99492–99494, G2214, 99484, or G0323 for the same patient-month.
8. Review denials weekly. Same-practitioner mismatches and missing bases will show up early if your enrollment process is loose.

For oncology-aligned CoCM programs that are not APCM homes, run a parallel checklist on 99492 / 99493 minutes and psychiatric-consultant caseload reviews. Do not force those patients onto G0568 just because the add-on feels easier.

Common failures that still show up in 2026

Add-on without APCM. The claim looks complete to a biller who only checks that G0568 is active on the chargemaster. Medicare sees an add-on with no base.

APCM and add-on under different NPIs. Covering physicians, shared panels, and “behavioral health directs CoCM while PCP bills APCM” arrangements break MM14315’s same-practitioner rule.

Calling every behavioral health touch CoCM. No psychiatric consultant, no registry, no weekly caseload review means you do not have G0568 or G0569. You may have G0570, or you may have ordinary E/M and psychotherapy codes instead.

Billing G0568 every month forever. Initial vs subsequent still matters. Treat G0568 like an episode start, not a preferred higher code.

Double path billing. APCM add-on plus 99492 in the same month for the same patient for comparable CoCM work is the fast way to a take-back.

Assuming specialty clinics can bill APCM casually. If you are not responsible for all primary care and not the focal point for needed health care services, you are outside APCM. Use standalone CoCM when you qualify as treating practitioner, or coordinate with the primary care practice.

Consent gaps. Missing the one-provider APCM disclosure or the BHI specialist-consultation consent creates both payment and beneficiary-notice risk.

Minute-log whiplash. Teams either keep unnecessary minute tracking for the add-ons (wasted labor) or delete clinical documentation along with the minute log (audit risk). Keep the clinical record. Drop only the payment-threshold minute math for G0568–G0570.

Ignoring FQHC / RHC claim mechanics. The add-ons are payable there at non-facility PFS rates, but the claim format and care-coordination instructions differ from a freestanding physician office. Read MLN006397 or MLN006398 before copying an office workflow.

What September 14, 2026 still changes: CY 2027 valuation, not 2026 coding

Nothing in this section changes how you bill dates of service in 2026. It does change what you should tell CMS before the comment window closes.

On July 14, 2026, CMS issued the CY 2027 PFS proposed rule (CMS-1848-P). Comments are due September 14, 2026. The CMS fact sheet confirms the broader behavioral health and chronic-disease package, including bringing smoking and tobacco-use cessation and SBIRT into the final year of the timed behavioral health work-RVU transition, and proposing separate coding for shared medical appointments.

Specialty societies summarizing the display copy also report proposed work-RVU increases for psychiatric CoCM and for the APCM CoCM add-ons so that G0568 and G0569 stay aligned with the standalone CoCM family, plus a proposed increase in the behavioral health care manager clinical labor rate used in PE calculations. Those valuation details are proposals until a final rule issues. Do not update your 2026 expected-reimbursement spreadsheet as if they were final. Do put them in a comment if CoCM sustainability depends on accurate work and clinical-labor valuation.

Practical comment themes for practices that actually run CoCM with APCM:

• Whether proposed work RVUs for 99492, 99493, 99494, G2214, G0568, and G0569 reflect real treating-practitioner and psychiatric-consultant decision-making.
• Whether the behavioral health care manager clinical labor crosswalk matches who actually fills that role in independent practices.
• How shared medical appointment coding (placeholder GSMAS in summaries of the proposed rule) should interact with existing care management and BHI programs so group visits do not create accidental duplicate billing.
• Operational friction in the same-practitioner rule for clinically integrated teams that share panel coverage.

File comments at regulations.gov under file code CMS-1848-P. Silence is how draft valuation becomes next year’s fee schedule.

Recommendations for the rest of 2026

1. Decide whether you are an APCM practice. If yes, finish enrollment, consent, care-plan, and performance-measurement infrastructure before chasing add-on revenue.
2. Stand up or clean up the clinical model first. CoCM needs a care manager, psychiatric consultant, registry, and weekly reviews. General BHI needs systematic monitoring and an appointed continuity lead.
3. Rebuild claim edits around same NPI + same month + single pathway. This is higher value than another chargemaster memo.
4. Train on initial vs subsequent. G0568 is an episode-start code on the APCM path. G0569 is the continuation code.
5. Keep oncology and other specialty CoCM on standalone codes unless that specialty clinician truly meets APCM primary care focal-point rules.
6. Comment by September 14 if CoCM payment adequacy matters to your program.
7. Audit ten charts a month for consent, rating scales, registry evidence, and practitioner match. Fix process errors before MAC review does.

Conclusion

G0568, G0569, and G0570 are optional, non-time-based APCM behavioral health add-on codes effective January 1, 2026. They pay for real CoCM or general BHI furnished in the same month as G0556, G0557, or G0558 by the same practitioner. They do not create a shortcut around team-based care, consent, registries, or psychiatric consultation. They also do not turn every specialty clinic into an APCM billing site.

Get the pathway right, match the practitioner, keep the clinical evidence, avoid stacking comparable standalone codes, and use the September 14, 2026 comment deadline to speak to 2027 valuation. That is how the 2026 add-ons become reliable monthly revenue instead of another denial queue.