When CMS finalized the CY 2025 Medicare Physician Fee Schedule, it created new Advanced Primary Care Management (APCM) codes that became effective January 1, 2025. These codes were designed to better support practices delivering comprehensive, team-based primary care—particularly for patients with multiple chronic conditions who require ongoing coordination and follow-up.
But if your organization decided to hold off on implementing APCM for 2025, a new proposal for 2026 may change your mind.
In the CY 2026 Proposed Rule released July 14, 2025, CMS announced plans to expand the APCM framework with optional behavioral health add-on codes. These new G-codes would allow practitioners who bill the APCM base code to also bill for Behavioral Health Integration (BHI) or Collaborative Care Model (CoCM) services in the same month—capturing work that often goes uncompensated under traditional fee-for-service.
This is more than just another set of codes. It’s an acknowledgment that behavioral health conditions are among the most common chronic conditions in the U.S., and that managing physical health without addressing co-occurring behavioral health needs rarely delivers the best results. Integrated care improves depression severity, helps patients manage other chronic conditions more effectively, and enhances the overall patient experience.
By adding optional behavioral health services directly onto APCM, CMS is trying to make it easier for primary care teams to wrap these critical services into their workflows without unnecessary billing barriers. The agency is also requesting input on whether preventive services could be incorporated into future APCM bundles—signaling even more potential to reward whole-person care under a single, predictable payment structure.
For practices that decided the administrative lift of APCM didn’t pencil out for 2025, this new behavioral health option could tip the scales—especially for clinics and health centers already investing in integrated behavioral health but struggling to capture sustainable reimbursement for it.
What Should You Do Now?
Now is the time to revisit your decision. Review how your team currently delivers behavioral health services, assess how they could align with the proposed add-on codes, and consider submitting comments to CMS while there’s still time to shape how these changes take effect.
The opportunity to expand APCM could make a real difference for patients—and help your care team get paid for work you’re already doing. If you’d like help mapping this out for your practice, let’s talk.