Last updated: November 2026
The Collaborative Care Model (CoCM) is a Medicare behavioral health integration model that a primary care team provides: a treating billing practitioner, a behavioral health care manager and a psychiatric consultant share a caseload, and Medicare pays the billing practitioner by the calendar month. A CoCM program build is the written program a practice puts in place before it enrolls its first patient: roles, registry workflow, consent script, monthly time log and billing checks. Integral Healthcare Solutions (IHS) is a consulting firm. It drafts those documents, and your clinicians approve all clinical content.
This is IHS program development work, one of three practice lines alongside accreditation consulting and compliance services. It is not coding, billing, clinical or legal advice. The CMS documents cited were opened November 5, 2026.
What is the Collaborative Care Model in Medicare?
CoCM is one of two BHI service types Medicare covers; the other is general BHI using care models other than CoCM (booklet p. 4). The governing CMS text is the CMS MLN booklet MLN909432, Behavioral Health Integration Services, January 2026 edition. The CMS Care Management page, last modified November 3, 2026, links the same booklet. Where this page uses the older CMS BHI billing FAQs (December 5, 2023), it says so. This page names no CPT or HCPCS code numbers and no payment amounts; the booklet carries an AMA copyright notice on its code descriptions. Read current rates from CMS.
What CoCM adds to primary care
CoCM "enhances usual primary care by adding 2 key services, particularly for patients whose conditions aren't improving": care management support for patients receiving behavioral health treatment, and regular psychiatric inter-specialty consultation (p. 5). Patients may be eligible if they have "an identified mental, behavioral, or psychiatric health condition, including substance use disorder" and need an assessment, care planning and interventions (p. 3).
The team of three
The booklet says "A team of 3 delivers psychiatric CoCM services" (p. 5). The care manager is "A designated provider with formal education or specialized training in behavioral health, including social work, nursing, or psychology, working under the oversight and direction of the billing practitioner." The psychiatric consultant is "A medical provider trained in psychiatry and qualified to prescribe the full range of medications."
The care manager administers validated rating scales, updates care plans, delivers brief psychosocial interventions and maintains the patient registry (p. 11). The consultant "Isn't generally expected to have direct patient contact, prescribe medications, or deliver other treatment directly to the patient" (p. 12).
The monthly service
The care manager "Follows up proactively and systematically using validated rating scales and a registry" and provides "at least 70 minutes of behavioral health care manager time in the first month and at least 60 minutes or more in the following months." The care manager and psychiatric consultant "conduct regular caseload reviews weekly, including the patient's treatment plan and status" (p. 6).
Consent and cost sharing
Before BHI services start, the patient must give the billing practitioner permission to consult with relevant specialists, including a psychiatric consultant, and the billing practitioner must inform the patient that cost sharing applies. CMS does not require written consent. The booklet says "You may get verbal consent from the patient" and "You must document it in the medical record," and a new consent is required "only if the patient changes billing practitioners" (p. 4).
How an episode ends
"The episode ends when the patient meets targeted treatment goals, doesn't meet them and the team refers them for direct psychiatric care, or has a break in care with no CoCM for 6 consecutive months" (p. 5).
Where the registry fits
The booklet's diagram places a registry in the model, and its text has the care manager maintain it (pp. 5, 6, 11). It does not say what system must hold the registry or what fields it must carry. Those are design choices for your clinicians and EHR, and IHS drafts them as such.
Who builds a CoCM program, and what triggers it?
A primary care group builds a CoCM program when it plans to add psychiatric collaborative care, and so does a specialty practice adding behavioral health. The booklet lists physicians of any specialty, physician assistants, nurse practitioners, clinical nurse specialists and certified nurse midwives as practitioners who may bill BHI (p. 3). Common triggers: a decision to start CoCM, a plan to staff the care manager and consultant roles, or a billing review that finds time or consent documentation missing.
How does IHS help build a CoCM program?
IHS writes the program on paper first, so your team can test it against the booklet before enrolling a patient. Dr. Thomas G. Goddard leads the work. The steps:
- Read the current CMS booklet with your leaders and list the conditions the program must meet.
- Draft the program design and role descriptions for the billing practitioner, care manager and psychiatric consultant, in the booklet's team language.
- Draft the registry workflow: enrollment, tracking with validated rating scales, weekly review and closing an episode.
- Draft the consent script and form: permission to consult a psychiatric consultant, the cost-sharing notice, and documentation in the medical record.
- Draft the monthly time log and the billing-control checklist your billing staff run before each claim.
- Run a mock review of a sample of records against the checklist, so gaps surface before a claim does.
What you supply. Your clinicians approve all clinical content. You supply the psychiatric consultant agreement, the care manager hires, and the EHR registry capability.
The real limit. IHS is not a coding service and supplies no registry software. State rules on consultants and Medicaid coverage vary and are not covered here.
What should you have ready before building a CoCM program?
Each item ties to the CMS MLN booklet MLN909432, Behavioral Health Integration Services (January 2026), read November 5, 2026.
- A named billing practitioner who directs the care manager and stays involved (pp. 5, 11).
- A designated behavioral health care manager with formal education or specialized training in behavioral health, available to deliver services face-to-face (pp. 5, 11).
- A psychiatric consultant trained in psychiatry and qualified to prescribe the full range of medications, employed or under contract (pp. 3, 5).
- A consent process that records permission to consult a psychiatric consultant and the cost-sharing notice in the medical record (p. 4).
- Validated rating scales chosen by your clinicians (p. 6).
- A registry and a weekly caseload review between the care manager and the consultant, with a record that each one happened (p. 6; IHS design choice).
- A monthly time log that counts care manager time toward the thresholds and excludes time spent solely on administrative or clerical duties (pp. 6, 11).
- A rule for the three episode end conditions and a record of which one applied (p. 5).
- A monthly check that each patient is under CoCM or general BHI, not both (p. 9).
The free introductory call turns that list into a program.
How does CoCM compare with general BHI and other care management?
The table sets out what the booklet says. The two cannot be reported for the same patient in the same month (p. 9).
| Question | CoCM | General BHI |
|---|---|---|
| Who is on the team | Billing practitioner, behavioral health care manager and psychiatric consultant (p. 5) | Billing practitioner, with clinical staff as the model uses them; a care manager or consultant is optional (pp. 9, 11, 12) |
| Registry and weekly caseload review | Described as part of the model (pp. 5, 6) | Not described as a requirement; the care model must systematically assess and monitor patients (p. 9) |
The FAQs (December 5, 2023) say chronic care management and BHI "are distinct services although there is some overlap in eligible patient populations." They say both can be billed for the same patient in the same month if advance consent for both services and all other requirements for each are met and time and effort are not counted more than once. See the IHS chronic care management program build page.
What does a CoCM program build cost?
The cost has three parts. Authority fees: the booklet sets no fee to start a CoCM program; it describes Medicare payment, and this page states no amounts. Verify current rates with CMS.
Consulting: IHS scopes each engagement after a free introductory call, and this page carries no IHS figure. Scope moves with the number of sites and care teams, the EHR registry capability and how much documentation already exists.
Internal staff time: clinicians approve clinical content, and billing staff test the control checklist.
What this is not
- It is not clinical, coding, billing or legal advice, and clinicians approve all clinical content.
- It does not guarantee payment, and IHS supplies no registry software.
- IHS does not submit claims. Your practice bills and corresponds with its Medicare Administrative Contractor.
Frequently asked questions
What is the Collaborative Care Model in Medicare?
CMS says "Psychiatric CoCM is a BHI model that a primary care team provides" (CMS MLN booklet MLN909432, Behavioral Health Integration Services, p. 5). IHS drafts the program documents around that structure.
What qualifies a behavioral health care manager?
The booklet describes "A designated provider with formal education or specialized training in behavioral health, including social work, nursing, or psychology, working under the oversight and direction of the billing practitioner" (p. 5). The CMS BHI billing FAQs (December 5, 2023) add that Medicare did not specify a minimum education requirement.
Does the psychiatric consultant have to be in our practice or on staff?
No. The FAQs (December 5, 2023) say they "may, but are not required to be, employees in the same practice as the billing practitioner"; they are employees or work under contract to the billing practitioner. The booklet says the consultant "can (and typically will) be remotely located" (p. 12).
What consent does CoCM require?
The patient must first give the billing practitioner permission to consult with relevant specialists, including a psychiatric consultant. The booklet says CMS does not require written consent, "You may get verbal consent from the patient," and "You must document it in the medical record" (p. 4). A new consent is required only if the patient changes billing practitioners.
Does the patient owe cost sharing for CoCM?
The booklet says "The billing practitioner must inform the patient that cost sharing applies for both face-to-face and non-face-to-face services even if supplemental insurers cover cost sharing" (p. 4).
When does a CoCM episode of care end?
The booklet says it "ends when the patient meets targeted treatment goals, doesn't meet them and the team refers them for direct psychiatric care, or has a break in care with no CoCM for 6 consecutive months" (p. 5).
Can we bill general BHI and CoCM for the same patient in the same month?
No. The booklet says "You may not report general BHI codes in the same month as psychiatric CoCM codes for the same patient," but it may be appropriate to report one or the other over the course of several months (p. 9).
What does IHS draft, and what do our clinicians approve?
IHS drafts the program design and roles, registry workflow, consent script, monthly time log and billing-control checklist. Your clinicians approve all clinical content and supply the consultant agreement, care manager hires and EHR registry capability. IHS scopes each engagement after a free introductory call.