Employer guide · Planning your team and staffing model

Staffing the Collaborative Care Model: Care Manager, Psychiatric Consultant, Billing Provider

The three roles Medicare's CoCM requires, what CMS actually says about each person's qualifications, and how the 70- and 60-minute thresholds turn into a hiring plan.

Updated October 7, 2026

The Collaborative Care Model runs on three people, and CMS names them: the treating (billing) practitioner who bills Medicare, a behavioral health care manager with formal education or specialized training in behavioral health, and a psychiatric consultant trained in psychiatry.

CMS sets no license for the care manager role — but it does set minimum care-manager minutes per patient, 70 in the first month and 60 in later ones, and those minutes are what actually determine your headcount.

Rules vary by state and change

This guide explains federal rules and the state rules it names, as of the date above.

Licensure, supervision, payer and employment rules differ by state and are revised often, so confirm current requirements with your state board, Medicaid agency, labor department or employment counsel before you act on them.

It is general information, not legal advice.

What the Collaborative Care Model is

Collaborative Care (CoCM) is a team-based behavioral health service that Medicare pays for inside medical practices: a treating practitioner manages patients' behavioral health conditions with psychiatric backup, and a care manager keeps each patient moving between visits.

In CMS's Behavioral Health Integration Services booklet (MLN909432, January 2026), the service is delivered by a team of three — a behavioral health care manager, a psychiatric consultant and the treating (billing) practitioner.

The treating practitioner is typically a primary care clinician, but CMS notes the role can sit in other specialties and names cardiology and oncology as examples.

The model has a defined arc.

It starts with consent: before services begin, the patient must agree to BHI — verbal consent documented in the record is enough — and be told that cost sharing applies.

It ends when CMS says it ends: the patient meets treatment goals, fails to meet them and is referred for direct psychiatric care, or goes six consecutive months with no CoCM.

For staffing, that last condition matters — the registry is a roster of active episodes, not a permanent subscription.

This page is about the staffing consequences: who the three roles are, what qualifications CMS actually attaches to each, and how the per-patient minutes behind the CoCM codes tell you how many people to hire.

The three required roles and what CMS says about each

CMS's booklet is specific about who does what.

Here is the team it describes, with the hiring note for each seat.

RoleWhat CMS requiresWhat it means for hiring
Treating (billing) practitionerA physician or non-physician practitioner (physician assistant or nurse practitioner), typically working in primary care but possibly another specialty. Medicare lets physicians of any specialty, PAs, NPs, clinical nurse specialists and certified nurse midwives bill BHI, as long as their scope of practice includes E/M services.A chair you may already have filled — this person bills Medicare directly and carries the team's oversight.
Behavioral health care managerA designated provider with formal education or specialized training in behavioral health — the booklet names social work, nursing and psychology — working under the oversight and direction of the billing practitioner. May or may not be someone who can independently bill Medicare; administrative or clerical staff do not qualify.Your primary new hire. Detailed in the next section.
Psychiatric consultantA medical provider trained in psychiatry and qualified to prescribe the full range of medications, who can — and typically will — be remotely located, and is not generally expected to see patients directly or prescribe.A part-time relationship, not a full-time prescriber. Covered further down.

Two structural rules shape every hiring decision in the model.

First, care team members must be employees of, or working under contract with, the billing practitioner, and their services are furnished incident to the billing practitioner's services, subject to state law and scope of practice — our guide to incident-to billing explains how that arrangement works.

Second, Medicare assigns BHI services the billing practitioner does not personally perform to general supervision, which does not require the practitioner's physical presence.

The care manager can work with patients when the practitioner is not in the building.

Qualifications for the behavioral health care manager

Start with what CMS does not require: a specific license.

The booklet's definition asks for a designated provider with formal education or specialized training in behavioral health, naming social work, nursing and psychology as included fields — it names no license and no degree level.

Whatever the hire's credentials, state scope-of-practice law still governs what they may actually do, so map the duty list against your own state's rules before you write the posting.

For a picture of who actually holds the job, the University of Washington AIMS Center — the academic program that developed the model — says behavioral health care managers are typically clinical social workers, licensed counselors, nurses or psychologists, and adds that in some contexts the care manager may not be licensed.

AIMS also makes the hiring point bluntly: the ability to perform, assign and plan the work matters more than the credentials one holds.

That is program guidance, not Medicare rule — but it is the guidance the model grew up with.

Write the job description around CMS's duty list, because those duties are what the minutes pay for: administering validated rating scales, building and revising care plans, delivering brief psychosocial interventions, maintaining the patient registry, and consulting the psychiatric consultant.

Around the task list sit three availability expectations: a continuous relationship with the patient, the ability to see patients face-to-face, and the ability to work outside regular clinic hours as necessary.

That last one is a scheduling decision, not a slogan — build it into the posted schedule and the pay discussion.

Two notes from CMS's fine print.

The care manager may or may not be a practitioner who can independently bill Medicare, so a clinician who cannot bill in their own name can still hold the role.

And the time that counts toward CoCM minutes is care-manager time: administrative and clerical staff do not qualify, so this is a clinical hire, not a gap filled from the front desk.

When you are ready to source candidates, our role guide to hiring a case manager covers the market, screening and pay context for this corner of behavioral health.

The psychiatric consultant: employed or contracted

CMS's definition is a medical provider trained in psychiatry and qualified to prescribe the full range of medications.

Two design features follow from the rest of the booklet: the consultant can — and typically will — be remotely located, and is not generally expected to see patients directly, prescribe, or deliver other treatment to the patient.

Prescribing generally stays with the treating practitioner; the consultant's job is advice.

The AIMS Center describes the cadence: the consultant joins the care manager for caseload reviews and recommends treatment changes when a patient is not at least 50% improved after 10 to 12 weeks on a treatment plan.

The weekly review is not optional color — CMS requires the care manager and psychiatric consultant to conduct regular caseload reviews weekly.

On volume, AIMS estimates 2 to 3 hours per week of psychiatric consultant time for each full-time or nearly full-time care manager managing a full caseload, including the systematic caseload review.

That estimate is the whole business case for the contracted model: you are buying a few hours a week of psychiatric time, not a line on the daily schedule.

CMS's employment rule allows either shape: care team members may be employees of, or under contract with, the billing practitioner.

An employed consultant is simplest for scheduling and availability, but pays for far more availability than 2 to 3 hours a week uses.

A contracted consultant matches the shape of the work — AIMS describes a consultant who does not normally see patients and may be available during business hours for ad-hoc consultation, which is a service level you can write into a contract.

Whichever way you go, put the weekly review, the response expectations and registry access in writing before the first patient enrolls.

Minutes, codes and what they mean for staffing

CoCM is paid against care-manager minutes, and the thresholds are your staffing arithmetic.

CMS requires at least 70 minutes of behavioral health care manager time in the first month of an episode and at least 60 minutes in each following month, with weekly caseload reviews between the care manager and the psychiatric consultant throughout.

The codes parcel those minutes:

  • CPT 99492 — the first 70 minutes of care manager activity in the first calendar month.
  • CPT 99493 — the first 60 minutes in a subsequent month.
  • CPT 99494 — each additional 30 minutes.
  • HCPCS G2214 — the first 30 minutes in a month.

The billing practitioner is not a bystander in the time math.

CMS's coding table assumes 30 minutes of billing-practitioner time for 99492, 26 minutes for 99493 and 13 minutes for 99494 — budget for that time when you set the practitioner's schedule, or the model will quietly cannibalize visit slots.

A lighter alternative exists.

General BHI (CPT 99484) requires at least 20 minutes of clinical staff time per month and requires neither a psychiatric consultant nor a care manager — and Medicare bars reporting general BHI codes in the same month as CoCM codes for the same patient.

There is also a dedicated code for psychology- and social-work-led programs: HCPCS G0323 lets a clinical psychologist or clinical social worker bill at least 20 minutes per month of behavioral health care management, with a psychiatric diagnostic evaluation (90791) as the initiating visit.

If your minutes projection says your population does not need the full three-person team, one of these is the honest staffing answer.

One 2026 change belongs in your billing setup rather than your org chart: from January 1, 2026, CMS added optional add-on codes — G0568 and G0569 for CoCM, G0570 for general BHI — for patients also receiving advanced primary care management (APCM).

They are not time-based, so they change claims, not headcount.

Deliberately absent from this page: dollar figures.

Medicare payment amounts for the CoCM codes should be pulled from CMS's current Physician Fee Schedule for your locality when you build the budget — a staffing model built on a stale reimbursement figure is wrong before it starts.

Hiring order and caseload

A workable sequence, starting from an existing medical staff: confirm the billing practitioner, hire the care manager, then line up the consultant relationship.

The ordering is about calendar and cash — the care manager's registry takes time to fill, while a contracted consultant can start with a single standing meeting.

Hire the care manager at full-time or nearly full-time from the start.

That is the AIMS Center's recommendation, and it has evidence behind it: AIMS cites a study (Moise et al., 2018) in which clinics with a 0.5 FTE care manager were less likely to sustain their Collaborative Care programs than clinics with care managers at higher FTEs.

AIMS also notes a single care manager may need to cover two or more small clinics — relevant if you run multiple sites.

On caseload, CMS sets minutes per patient and no ceiling — the ceiling is arithmetic, not regulation.

The AIMS Center's illustrations sketch 80 patients for a full-time care manager working partly virtually with common adult depression and anxiety or a commercially insured population, and 60 for more complex, pediatric or geriatric, or Medicaid- and uninsured-serving FQHC populations.

Those are illustrations, not standards.

The assumptions behind them matter more than the numbers: AIMS builds both figures on a care manager spending 75% of their time on direct care, which leaves 130 hours a month for appointments.

Run your own version of that math — your direct-care share, your population — instead of importing someone else's caseload.

Leave slack.

AIMS warns that a caseload that is too high can hurt staff morale and retention — and it is the care manager who holds the program's continuous patient relationships.

When the registry outruns the minutes, the fix is a second hire — the behavioral health hiring hub collects the employer guides for everything that comes next, from screening to pay models.

Before your first CoCM patient

  • Confirm the billing practitioner: a physician, PA, NP, clinical nurse specialist or certified nurse midwife whose scope of practice includes E/M services.
  • Write the care manager posting around CMS's duty list — validated rating scales, care plans, brief psychosocial interventions, the patient registry and psychiatric consultation.
  • Verify the hire's formal education or specialized training in behavioral health, and map the duties against your state's scope-of-practice law.
  • Choose employed or contracted for the psychiatric consultant, and put the weekly caseload review on both calendars before the first patient enrolls.
  • Script the consent conversation: verbal consent documented in the record is enough, and the patient must be told cost sharing applies.
  • Plan capacity in minutes — at least 70 per new patient in month one, at least 60 per active patient per month after — and re-check the load against morale and retention.

Questions employers ask

Does the behavioral health care manager have to be an LCSW?

No. CMS's definition asks for formal education or specialized training in behavioral health and names social work, nursing and psychology as fields that qualify — it sets no specific license and no degree level.

The University of Washington AIMS Center says care managers are typically clinical social workers, licensed counselors, nurses or psychologists, and that in some contexts the care manager may not be licensed.

Your state's scope-of-practice law still governs what your hire may actually do.

Can you bill CoCM without a psychiatric consultant?

Not CoCM itself — the model is built on the three-person team, and weekly caseload reviews between the care manager and the consultant are part of the service.

The lighter option, general BHI (CPT 99484), requires at least 20 minutes of clinical staff time a month and needs neither a care manager nor a consultant.

Medicare bars reporting general BHI and CoCM codes in the same month for the same patient, so pick the model that matches your staffing.

Does the psychiatric consultant have to be on staff?

No. CMS allows care team members to be employees of, or under contract with, the billing practitioner, and describes the consultant as able — and typically located — remotely, with direct patient contact not generally expected.

The AIMS Center estimates 2 to 3 hours of consultant time per week for each full-time care manager with a full caseload, which is why a contracted part-time arrangement fits the shape of the work.

How many patients can one care manager carry?

CMS sets minutes per patient per month, not a caseload limit — at least 70 minutes in the first month and at least 60 in following months.

The AIMS Center's illustrations run 80 patients for a full-time care manager working partly virtually with common adult depression and anxiety, and 60 for more complex or Medicaid- and uninsured-serving populations.

They are illustrations, not standards, and AIMS warns that an overloaded caseload can hurt morale and retention.

What happens when a CoCM episode ends?

CMS ends the episode when the patient meets treatment goals, when goals are not met and the patient is referred for direct psychiatric care, or after six consecutive months with no CoCM.

For staffing, the practical effect is roster turnover: the registry is not a permanent subscription, and patients who finish free the minutes that let you enroll new ones without adding staff.

Sources

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