Billing Medicare for Behavioral Health Integration (BHI)
Behavioral Health Integration (BHI)
CCM Services versus BHI services
There are substantial differences in the potential number and nature of conditions, types of individuals providing the services, and time spent providing services. CCM involves care planning for all health issues and includes systems to ensure receipt of all recommended preventive services, whereas Behavioral Health Integration (BHI) care planning focuses on individuals with behavioral health issues, systematic care management using validated rating scales (when applicable), and does not focus on preventive services. CCM requires the use of certified electronic health information technology, whereas BHI does not. In most cases, it would not be difficult to determine which set of codes (BHI or CCM) more accurately describe the patient and the services provided. If a BHI service code more specifically describes the service furnished (service time and other relevant aspects of the service being equal), then it is more appropriate to report the BHI code(s) than the CCM code(s).
CCM and BHI in Same Month
CCM and BHI are distinct, differing services even though there is some overlap in eligible patient populations. There may be some circumstances in which it is reasonable and necessary to provide both services in a given month. The Behavioral Health Integration (BHI) codes can be billed for the same patient in the same month as CCM if advance consent for both services and all other requirements to report BHI and to report CCM are met and time and effort are not counted more than once. Billing practitioners should keep in mind that cost-sharing and advance consent apply to each service independently and there can only be one reporting practitioner for CCM each month. If all requirements to report each service are met, both may be billed.
Date of Service (DOS)
The BHI service period is one calendar month. Centers for Medicare and Medicaid Services (CMS) expects the billing practitioner to continue furnishing services during a given month, if medically necessary, even after the time threshold to bill BHI is met. However, after completion of the minimum clinical staff service time required to bill, the practitioner may submit the claim and need not hold the claim until the end of the month.
Place of Service (POS)
The BHI codes are priced in both facility and non-facility settings. The billing practitioner should report the POS for the location where he or she would ordinarily provide face-to-face care to the beneficiary.
The BHI codes can be billed (directly reported) by physicians and non-physician practitioners whose scope of practice includes evaluation & management (E/M) services and who have a statutory benefit for independently reporting services to Medicare. This includes physicians of any specialty, physician assistants, nurse practitioners, clinical nurse specialists, and certified nurse-midwives. Generally, CMS would not expect psychiatrists to bill the psychiatric CoCM codes, because psychiatric work is defined as a sub-component of the psychiatric CoCM codes. However, General BHI could be billed by a psychiatrist who furnished the services described by the general BHI code and met all requirements to bill it.
BHI Initiating Visit
For new patients or patients not seen within a year prior to the commencement of BHI services, BHI must be initiated by the billing practitioner during a “comprehensive” Evaluation & Management (E/M) visit, annual wellness visit (AWV) or initial preventive physical exam (IPPE). This face-to-face visit is not part of the BHI service and can be separately billed under the PFS, but is required before BHI services can be provided. The billing practitioner must discuss BHI with the patient at this visit. While informed patient consent does not have to be obtained during this visit, it is an opportunity to obtain the required consent. The face-to-face visit included in transitional care management (TCM) services (CPT codes 99495 and 99496) qualifies as a “comprehensive” visit for BHI initiation.
Levels 2 through 5 E/M visits (CPT codes 99202-99205 and 99212-99215) also qualify; CMS is not requiring the practice to initiate BHI during a level 4 or 5 E/M visit. However, CPT codes that do not involve a face-to-face visit by the billing practitioner or are not separately payable by Medicare (such as CPT code 99211, anticoagulant management, online services, telephone and other E/M services) do not meet the requirement for the visit that must occur before BHI services are furnished. If the practitioner furnishes a “comprehensive” E/M, AWV, or IPPE and does not discuss BHI with the patient at that visit, that visit cannot count as the initiating visit for BHI.
BHI and Telehealth
The BHI codes allow for remote provision of certain services by the psychiatric consultant and other members of the care team. For CoCM, the behavioral health care manager must be available to provide face-to-face services in person, but provision of face-to-face services is not required. The BHI codes do not describe services that are subject to the rules for Medicare telehealth services in the narrow meaning of the term (under section 1834(m) of the Social Security Act).
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