What changed, and when: CMS released the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) with a CMS fact sheet on July 14, 2026, and published it in the Federal Register on July 16, 2026. The rule continues the buildout of integrated behavioral health payment pathways that began with the behavioral health integration codes established in the CY 2023 through CY 2025 PFS final rules. Comments are due September 14, 2026.
The signal for practices is direct. CMS is leaning into evidence that patients with chronic physical conditions do better when co-occurring behavioral health concerns are managed together, and it is placing new PFS dollars behind integrated care management even as the conversion factor falls. Primary care and behavioral health groups should inventory the BHI and collaborative care codes they already bill, then get comments in before the window closes.
Half the comment window is already gone
Integration is where the new dollars are appearing
Read across the last several cycles and the pattern is unmistakable. The CY 2023 through CY 2025 final rules established and expanded behavioral health integration and collaborative care payment, widened who can deliver the behavioral health portion of the work, and treated care management as infrastructure worth paying for. CMS-1848-P extends that arc into chronic condition management for CY 2027.
The clinical logic is the policy logic. A patient managing diabetes, heart failure, or COPD alongside untreated depression or anxiety costs more and does worse. CMS's proposals reflect the evidence that managing the two together changes outcomes, so the payment architecture keeps moving toward one integrated care plan rather than two parallel ones.
For practices, that creates an asymmetry worth acting on. The conversion factor pressure hits everything you bill. The integration pathways are where CMS is still adding, refining, and paying. Groups that already run BHI or CoCM programs have standing to tell CMS what works, what the time thresholds miss, and where documentation burden kills adoption. That is exactly what the comment file is for.
Integrated care management
New PFS dollars keep appearing here, cycle after cycle.
Conversion factor
Falling, which squeezes every code you bill the same way.
BHI code buildout
CY 2023 to CY 2025 laid the rails. CY 2027 extends them into chronic care.
Directional readouts of the rule's trajectory, not measured values.
Four dates that define this cycle
- CY 2023 to CY 2025Final rules establish and expand the BHI and collaborative care payment pathways
- Jul 14, 2026CMS fact sheet: CY 2027 PFS proposed rule (CMS-1848-P) released
- Jul 16, 2026Federal Register publication opens the comment period
- Sep 14, 2026Comments due to CMS
The integrated care code families to audit now
Before drafting a comment letter, know your own footprint. Pull twelve months of billing and map it against the code families Medicare already pays for integrated behavioral health, so your comments speak from utilization rather than theory.
General behavioral health integration care management, the entry point for practices without a full collaborative care team.
Psychiatric collaborative care management, the CoCM model with a behavioral health care manager and psychiatric consultant.
CoCM add-on for shorter monthly increments, useful for months that miss the base code time thresholds.
Behavioral health care management furnished by clinical psychologists or clinical social workers, from the recent buildout cycles.
Six moves before September 14, 2026
- Run a 12-month utilization report on 99484, 99492 through 99494, G2214, and G0323, and flag which are billed, denied, or never attempted.
- Read the CMS-1848-P fact sheet and the behavioral health and care management sections of the Federal Register text, not a summary of a summary.
- Model your chronic care panel: how many CCM patients carry a documented co-occurring behavioral health diagnosis that is not in an integrated care plan today.
- Cost out a CoCM or BHI staffing path if you have none, since the payment trajectory keeps rewarding practices with the infrastructure in place.
- Draft comments grounded in your own data: time thresholds, documentation burden, and staffing definitions are where operator input moves CMS.
- Submit to the docket for CMS-1848-P before September 14, 2026, and calendar the final rule watch for late fall.
- CY 2027 Physician Fee Schedule proposed rule, CMS-1848-P, CMS fact sheet, July 14, 2026.
- Federal Register, CY 2027 PFS proposed rule publication, July 16, 2026. Comments due September 14, 2026.
- CY 2023, CY 2024, and CY 2025 Physician Fee Schedule final rules, CMS, establishing and expanding behavioral health integration payment.
Turn the CY 2027 proposals into a billing plan
ASP-RCM Solutions runs the code inventory, models what CMS-1848-P would do to your chronic care and behavioral health revenue, and helps you stand up compliant BHI and CoCM billing with audited coding accuracy of 95 percent or higher. If integrated care management is where the new PFS dollars are appearing, your revenue cycle should already be pointed there.
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