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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 behavioral health add-ons 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.
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])
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).
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])
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 provide APCM services incident-to under general supervision, but this does not mean vendors count as staff. You must be able to defend that auxiliary personnel meet incident-to requirements while still tying the add-on to the APCM billing practitioner. ([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])
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])
- 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
Yes—the add-ons are optional. But if you bill them, the attachment requirements are mandatory. ([CMS])
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])
CMS’s finalized condition is “same practitioner” and “same month.” Design your workflow assuming the answer is no. ([CMS])
Treat it as the same billing professional who reports the APCM base code for that patient-month. ([CMS])
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])
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])
No. The add-ons are optional and require furnishing and documenting behavioral health integration with APCM. APCM validity is necessary but not sufficient. ([CMS])
Yes. CMS includes these add-on services when furnished with APCM in the primary care services definition for MSSP assignment starting 2026. ([CMS])
Split-practitioner reality (behavioral health under one clinician, APCM under another) collides with the same-practitioner requirement. ([CMS])
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])
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])
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])
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])
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])
- 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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