The opportunity and the risk
CMS is quietly reshaping how primary care teams can be paid for mental and emotional health support. Starting in 2026 (if finalized), practices using the new Advanced Primary Care Management (APCM) codes will be able to add small, monthly payments for behavioral health integration. It’s a major shift that rewards clinics for treating the whole person, not just physical symptoms. The risk is missing the operational readiness window: teams that wait until 2026 to understand the new codes will find themselves scrambling to align workflows and documentation.
A new layer in primary care payment
For years, CMS has talked about whole-person care, but reimbursement never fully caught up. The APCM model is changing that. If finalized, practices that already bill the new APCM care codes can tack on additional payments when their care includes mental health or substance-use management. In practical terms, it’s like saying: if you’re already managing a patient’s chronic conditions, and part of that care includes depression screening, counseling coordination, or medication oversight, CMS will pay you a little more for that extra work.
These new payments come through three add-on codes: GPCM1, GPCM2, and GPCM3. Each one ties to a real-world activity clinics already do but haven’t been fully reimbursed for.
The three behavioral health add-on codes in action
GPCM1 covers the first month of behavioral health integration. This includes identifying a mental health need, discussing options with the patient, and coordinating with a specialist. For example, a family doctor might screen for depression, develop an action plan, and consult with a psychiatrist about medication choices.
GPCM2 supports ongoing follow-up months. The clinic continues the plan, checks progress, and adjusts medications or referrals. Think of a nurse checking in weekly with the patient, tracking symptoms, and updating the psychiatrist as needed.
GPCM3 recognizes general behavioral health management directly within primary care. This applies when clinics provide counseling, medication monitoring, or mental health support without bringing in a psychiatrist. For instance, a nurse might help a patient manage anxiety symptoms and report progress to the doctor.
Clinics can only use these codes as add-ons to a monthly APCM claim. They’re optional but designed to fit naturally into what many primary care teams already do for patients with depression, anxiety, or substance-use conditions.
Why CMS is expanding behavioral health within APCM
The logic behind this change is straightforward: physical and mental health are deeply connected. Patients managing diabetes, heart disease, or chronic pain often struggle more when depression or anxiety go untreated. CMS wants to encourage clinics to address both at once, instead of sending patients elsewhere or letting mental health needs slip through the cracks.
This new approach does three key things:
It expands access. Clinics in rural and underserved areas, especially Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), will be able to bill for these services, bringing behavioral health support to communities where specialists are limited.
It reduces administrative friction. These new codes replace older behavioral health integration codes that required precise time tracking in minutes. The simplified structure means less paperwork and clearer billing for chronic and behavioral care that happens together.
It rewards realistic team-based care. Practices won’t need to overhaul systems or hire new staff to qualify. They can layer these add-ons on top of existing care management routines, using the same nurses, care coordinators, and medical assistants already involved in APCM activities.
What still needs clarification
As with any CMS update, the fine print isn’t final. The agency is still collecting feedback before it locks in the 2026 rule. Several operational details are open for comment, including how closely a psychiatrist or psychologist must supervise behavioral health activities, which care team roles are eligible to contribute, and how patient cost-sharing will be handled.
It’s also unclear whether these new APCM behavioral codes can be billed in the same month as the older behavioral health integration codes (99492–99494). CMS may require practices to choose one pathway to prevent double billing. Until the rule is finalized, practices should stay conservative in their planning and assume mutual exclusivity between the two sets of codes.
How practices can start preparing now
Forward-thinking clinics can take several steps in advance of 2026 to avoid being caught off guard. The most successful adopters will likely focus on three areas:
First, align clinical workflows. Map how behavioral health activities already show up in your APCM care process. Identify where screenings, follow-ups, or care coordination occur and who documents them. That clarity will make it easy to plug in the new codes when they’re approved.
Second, strengthen collaboration with mental health partners. If your practice occasionally refers to a psychiatrist, psychologist, or counselor, consider formalizing those relationships now. Shared templates, communication channels, and role clarity will make the transition smoother and compliant.
Third, get your billing and compliance teams ready. Talk to your EHR vendor and billing staff about upcoming APCM add-on logic. Make sure your documentation templates are flexible enough to capture behavioral health interventions without adding burden.
The compliance guardrails to keep in mind
Every new code introduces compliance risk if documentation doesn’t match the intent. Practices should be cautious about double counting services, overstating mental health involvement, or billing when behavioral health support wasn’t clearly provided. The safest approach is to document exactly what occurred that month: what mental health issue was addressed, who participated, what plan was made, and whether the patient agreed to ongoing monitoring.
It’s also important to remember that CMS still expects appropriate supervision for team-based activities. Even if direct psychiatrist oversight isn’t always required, the clinical documentation should show coordination and shared accountability. That’s especially critical for risk-bearing organizations or practices participating in value-based arrangements where behavioral health outcomes tie to performance metrics.
Why this matters for the future of primary care
This move from CMS signals a broader recognition that behavioral health can’t be treated as an add-on service. It’s a core part of whole-person care and, increasingly, of how primary care practices will be paid. If finalized, the APCM behavioral health add-ons could finally bridge the gap between chronic disease management and mental health treatment in everyday practice.
Early modeling suggests the financial impact won’t be massive per patient, but it can add up meaningfully across a large panel. More importantly, it gives clinics a practical framework to treat depression, anxiety, or substance-use issues as part of routine primary care—without needing to navigate multiple disconnected programs.
For leaders building sustainable primary care models, this is a moment worth watching closely. The clinics that prepare now—clinically, operationally, and financially—will be ready to take advantage of the shift when it becomes real.
Next steps
If your organization wants a clear roadmap for integrating behavioral health within APCM, request a 45-minute readiness review. We’ll walk through your current care management processes, identify where behavioral health naturally fits, and outline what preparation is worth doing before 2026.
This post is for informational purposes only; specific billing rules and reimbursement rates vary by MAC and payer.