5 Things You Need to Know About the 2026 CMS Behavioral Health Billing Updates

Behavioral health integration has been on CMS’s radar for years, but starting in 2026, major changes are coming that will reshape how practices can bill for collaborative care. These updates will cut administrative burden, expand who can deliver care, and make it easier to get reimbursed for the mental health services patients desperately need.

If your practice provides primary care or integrates behavioral health, here are the five things you need to know.

1. New Add-On Codes Are Coming

CMS is introducing three new HCPCS G-codes (GPCM1, GPCM2, GPCM3).

• These are add-on codes, designed to be billed with your Advanced Primary Care Management (APCM) codes.

• They allow you to bill APCM + Behavioral Health Integration (BHI) or Collaborative Care Model (CoCM) in the same month.

Until now, practices often had to choose which service to bill. In 2026, you’ll be able to capture the full scope of work you’re doing for patients with complex needs.

2. No More Stopwatch Documentation

One of the biggest frustrations with existing BHI and CoCM codes is the time requirement—documenting 20 minutes here, 30 minutes there.

Starting in 2026, CMS is removing strict time thresholds for these services.

Your team can focus on care, not clock-watching. Documentation will still need to show what was done, but you’ll no longer risk denials over missing a few minutes of tracked time.

3. Expanded Care Team Participation

For the first time, auxiliary staff under general supervision can perform the billable work that supports these codes.

That means:

• Who bills? Physicians, nurse practitioners (NPs), physician assistants (PAs), and clinical nurse specialists (CNSs).

• Who delivers services? Licensed clinical social workers (LCSWs), psychologists, nurses, care managers, and other auxiliary staff.

• Where? Not just traditional practices—Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) are included.

This expands your workforce. Practices can now leverage care managers and behavioral health staff more effectively, without restricting reimbursement to a single clinician’s time.

4. Settings That Will Benefit the Most

These changes are designed for primary care and integrated care settings. If you’re operating in:

• Family medicine

• Internal medicine

• Pediatrics

• FQHCs

• Rural Health Clinics

…you’re in the sweet spot for these codes.

Important note: Independent therapists (e.g., LMFTs, LPCs, solo psychologists) cannot bill these add-on codes directly. However, they can be part of the collaborative team providing the services, with the billing provider (physician, NP, PA, or CNS) submitting the claim.

5. What Your Practice Should Do Now

Preparation is key. Here’s how to get ready before January 2026:

• Audit your workflows: Are you already doing collaborative care work that isn’t fully reimbursed?

• Update billing systems: Ensure your EHR can handle the new GPCM codes.

• Train your care team: Social workers, nurses, and psychologists should know how their contributions will now be billable.

• Educate leadership: Especially in FQHCs and RHCs, these codes open doors to sustainable behavioral health integration.

• Communicate with payers: Stay ahead of payer updates on how they’ll implement CMS’s new codes.

The 2026 CMS billing updates for behavioral health aren’t just a policy tweak—they’re a major shift toward integrated care. By introducing add-on codes, eliminating time-based requirements, and broadening who can deliver billable services, CMS is signaling a clear direction: behavioral health should be part of primary care, and it should be reimbursed fairly.

For practices, this is both a compliance requirement and a revenue opportunity. Start preparing now, so by 2026 your workflows, staff, and billing systems are ready to go. We are here to help you develop workflow policies and procedures for your practice in line with these changes.