Guide

CoCM 99492–99494: what the collaborative-care model requires

Summary

Yes — a solo practice can bill the collaborative care codes, but only by building the three-role team CoCM requires: the treating practitioner, a behavioral health care manager, and a psychiatric consultant. 99492 bills the first month, 99493 each month after, and 99494 an add-on for extra time. The psychiatric consultant does not need to be an employee; a contracted, caseload-review relationship satisfies the requirement, which is what makes CoCM realistic without hiring a psychiatrist outright.

By Gale Editorial · Updated 2026-07-26. Every figure cited to a dated source. How we write.

Can a solo practice bill collaborative care codes?

Yes, but only by assembling the specific three-role team the collaborative care model requires: the treating practitioner managing the patient overall, a behavioral health care manager doing the recurring monitoring and coordination, and a psychiatric consultant reviewing the caseload and advising on treatment. CMS's behavioral health integration guidance describes these required care-team elements and the validated-rating-scale use that runs through the whole code family 1Ref 1Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.That Medicare pays for collaborative care management (99492-99494) and describes the required care-team elements and validated-rating-scale use, used here to explain the treating-practitioner, behavioral-health-care-manager, and psychiatric-consultant roles and the care manager's monthly monitoring work..

99492 bills the first calendar month of collaborative care for a patient, 99493 bills each month after that, and 99494 is an add-on for additional time beyond the base code's threshold. None of the three roles has to be an in-house employee — which is the detail that actually makes CoCM realistic for a practice of one, covered in the next section.

The three roles, and what each one actually does

The treating practitioner — typically the physician or other billing clinician managing the patient's overall care — stays accountable for the treatment plan and is the one billing the CoCM codes. The behavioral health care manager does the month-to-month work: outreach, monitoring with a validated tool, and coordinating between the treating practitioner and the psychiatric consultant. The psychiatric consultant reviews cases, usually as a caseload, and advises on treatment changes without seeing every patient directly 1Ref 1Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.That Medicare pays for collaborative care management (99492-99494) and describes the required care-team elements and validated-rating-scale use, used here to explain the treating-practitioner, behavioral-health-care-manager, and psychiatric-consultant roles and the care manager's monthly monitoring work..

That structure — one clinician managing the patient, one staff member doing the recurring monitoring, and one consultant advising at a caseload level rather than a visit level — is what CMS's guidance defines as required, and each piece has to be documented as functioning that way for the codes to be billed correctly.

Why a solo practice doesn't need to hire a psychiatrist

The psychiatric consultant role does not require an employment relationship — a contracted arrangement, where a psychiatrist reviews a caseload on a regular cadence and is reachable for consultation, satisfies what the model requires. For a solo practice, this usually means contracting with an outside psychiatrist for a defined number of hours a month rather than adding a full clinical hire, which is the piece that turns CoCM from theoretical to buildable for a practice of one.

Because that consultant is external and will be reviewing identifiable patient information to do the work, the relationship is a business associate arrangement under HIPAA, and it needs a business associate agreement spelling out how that information is handled before any case review happens 2Ref 2HHS Office for Civil Rights (2026).Business Associates.That a vendor creating, receiving, maintaining, or transmitting PHI on a practice's behalf is a business associate requiring a BAA, used here to explain that a contracted external psychiatric consultant reviewing patient cases needs a business associate agreement before that review begins.. Structuring the contract with clear expectations upfront — how many patients the consultant will review each month, how quickly they respond to a flagged case, and how the caseload gets shared securely — keeps the relationship functioning as the model requires rather than as an informal favor that quietly lapses.

The privacy housekeeping a contracted consultant relationship needs

Bringing on an external psychiatric consultant means protected health information is now flowing to a vendor outside the practice, which triggers the same Security Rule obligations that apply to any other business associate relationship — administrative, physical, and technical safeguards scaled to the size of the practice, anchored in a risk analysis 3Ref 3HHS Office for Civil Rights (2026).Summary of the HIPAA Security Rule.That the Security Rule requires administrative, physical, and technical safeguards for ePHI, scalable to practice size and anchored in a risk analysis, used here to explain the obligation a solo practice takes on once it shares PHI with an external psychiatric consultant.. A solo practice sized operation still owes that analysis; it is not a large-practice-only requirement.

ONC and OCR jointly publish a free Security Risk Assessment tool built for exactly this size of practice, which is a reasonable starting point for documenting that analysis rather than building one from scratch 4Ref 4Office of the National Coordinator / ASTP (2026).Security Risk Assessment Tool.That ONC and OCR publish a free Security Risk Assessment tool sized for small practices to conduct the risk analysis the Security Rule requires, used here as the starting point for documenting the risk analysis a CoCM practice owes once it contracts with an outside psychiatric consultant.. Doing this once, before the consultant relationship starts, is considerably less work than reconstructing it after a records request or a breach.

The behavioral health care manager's monthly work

The care manager's job is the recurring piece: outreach and check-ins, tracking the patient's status with a validated rating tool, and keeping the treating practitioner and psychiatric consultant looped in on changes — the required care-team elements and tool use CMS's guidance describes for the whole BHI and CoCM family 1Ref 1Centers for Medicare & Medicaid Services (2024).Behavioral Health Integration Services.That Medicare pays for collaborative care management (99492-99494) and describes the required care-team elements and validated-rating-scale use, used here to explain the treating-practitioner, behavioral-health-care-manager, and psychiatric-consultant roles and the care manager's monthly monitoring work.. How that scoring tool gets billed, including 96127 alongside e/m, is its own topic worth understanding separately.

For a solo practice, this role is usually an existing clinical staff member — a nurse, medical assistant, or behavioral health-trained team member — taking on the recurring monitoring rather than a new hire, which keeps the model's staffing cost closer to CCM's than to adding a second clinician.

Delivering care-manager contacts by phone or telehealth

Much of the behavioral health care manager's monthly contact happens by phone or video rather than in person, and whether a given contact currently qualifies for telehealth delivery is worth checking against CMS's telehealth list before building a workflow around it, since that list changes yearly and distinguishes permanent additions from temporary ones 5Ref 5Centers for Medicare & Medicaid Services (2026).List of Telehealth Services.That CMS publishes the definitive, year-to-year list of codes payable as Medicare telehealth, including permanent-versus-temporary status, used here as the check before delivering behavioral health care manager contacts by phone or video. As of July 2026..

Checking that list when the program is designed, and again whenever staffing or scheduling changes, keeps the delivery method matched to what is actually payable rather than what used to be.

Confirming coverage before you build the program

Whether a jurisdiction has published anything specific to collaborative care billing is searchable directly in the Medicare Coverage Database, which indexes both national coverage decisions and each MAC's own coverage articles 6Ref 6Centers for Medicare & Medicaid Services (2026).Medicare Coverage Database (MCD) Search.That national coverage decisions and MAC-specific coverage articles are searchable in the public Medicare Coverage Database, used here as the lookup method for jurisdiction-specific CoCM coverage guidance before building the program.. Checking this before committing to a contracted psychiatric consultant and a care-manager workflow is worth the time it takes, since CoCM represents a larger staffing and contracting commitment than most single-visit codes.

A solo practice weighing whether the collaborative care model is worth building, versus a lighter option like general behavioral health integration under 99484, should treat that as a genuine comparison rather than a foregone conclusion — CoCM pays for more because it requires more, and the right answer depends on whether a workable psychiatric consultant relationship is realistically available. Running that comparison honestly, rather than defaulting to whichever code a colleague already bills, is what actually determines whether the added structure CoCM requires is worth the added payment it brings.

Common questions

Yes, by assembling the three roles CoCM requires: the treating practitioner, a behavioral health care manager, and a psychiatric consultant. None of the three has to be a full-time employee — the care manager is often an existing staff member, and the psychiatric consultant is commonly a contracted, caseload-review relationship rather than a hire.

No. A contracted arrangement — a psychiatrist reviewing the caseload on a regular cadence and available for consultation — satisfies the requirement. That's the detail that makes CoCM buildable for a solo practice; because the relationship involves sharing identifiable patient information externally, it needs a business associate agreement in place first.

99492 bills the first calendar month of collaborative care for a given patient. 99493 bills each subsequent month. 99494 is an add-on code for additional time beyond the base code's monthly threshold. All three sit within the same care-team structure and documentation requirements.

99484 doesn't require a psychiatric consultant relationship — it's built around a validated rating tool and a behavioral health care plan managed by the treating practitioner's own care team. CoCM adds the psychiatric consultant role and its own set of monthly time-based codes, which is more structure but also a bigger staffing and contracting commitment.

A business associate agreement before any case information is shared, and the same HIPAA Security Rule risk analysis any practice sharing PHI with a vendor owes — administrative, physical, and technical safeguards scaled to the practice's size. ONC and OCR publish a free risk assessment tool built for a practice this size to use.

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References

1.Centers for Medicare & Medicaid Services (2024). Behavioral Health Integration Services. CMS Medicare Learning Network (MLN909432). link ✓That Medicare pays for collaborative care management (99492-99494) and describes the required care-team elements and validated-rating-scale use, used here to explain the treating-practitioner, behavioral-health-care-manager, and psychiatric-consultant roles and the care manager's monthly monitoring work.
2.HHS Office for Civil Rights (2026). Business Associates. U.S. Department of Health and Human Services. linkThat a vendor creating, receiving, maintaining, or transmitting PHI on a practice's behalf is a business associate requiring a BAA, used here to explain that a contracted external psychiatric consultant reviewing patient cases needs a business associate agreement before that review begins.
3.HHS Office for Civil Rights (2026). Summary of the HIPAA Security Rule. U.S. Department of Health and Human Services. linkThat the Security Rule requires administrative, physical, and technical safeguards for ePHI, scalable to practice size and anchored in a risk analysis, used here to explain the obligation a solo practice takes on once it shares PHI with an external psychiatric consultant.
4.Office of the National Coordinator / ASTP (2026). Security Risk Assessment Tool. HealthIT.gov. link ✓That ONC and OCR publish a free Security Risk Assessment tool sized for small practices to conduct the risk analysis the Security Rule requires, used here as the starting point for documenting the risk analysis a CoCM practice owes once it contracts with an outside psychiatric consultant.
5.Centers for Medicare & Medicaid Services (2026). List of Telehealth Services. Centers for Medicare & Medicaid Services (CMS). link ✓That CMS publishes the definitive, year-to-year list of codes payable as Medicare telehealth, including permanent-versus-temporary status, used here as the check before delivering behavioral health care manager contacts by phone or video. As of July 2026.
6.Centers for Medicare & Medicaid Services (2026). Medicare Coverage Database (MCD) Search. Centers for Medicare & Medicaid Services (CMS). link ✓That national coverage decisions and MAC-specific coverage articles are searchable in the public Medicare Coverage Database, used here as the lookup method for jurisdiction-specific CoCM coverage guidance before building the program.

https://www.gale.care/for-providers/em-cocm-99492-99494 · 6 sources. Competitor details are cited to dated public sources and maintained as they change; figures are estimates, not commitments. Synthetic demonstration.

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