A grounded look at what’s likely, what’s hype, and what leaders can do now.
Primary care is underwater. Behavioral health runs through nearly every panel. The real work—outreach, coordination, medication safety, patient messages—happens between visits, yet payment still tilts toward face-to-face time. That’s why so many leaders are watching the idea of a General Primary Care Management (GPCM) payment. Could a monthly, relationship-centered payment finally recognize the longitudinal work of primary care—behavioral health included?
Here’s the signal, grounded in CMS precedent and current models, and what to build now so you’re ready when policy lands.
What GPCM is (and isn’t)
In plain English, GPCM would be a monthly payment for general, longitudinal primary care management by a named team. It wouldn’t be tied to a single condition. It’s meant to stabilize ongoing work that keeps whole people on track—measurement, follow-up, medication monitoring, and coordination.
It’s not free money for “what you already do” without documentation. It won’t replace clinical judgment or visit-based care. And, based on longstanding CMS posture, don’texpect it to stack with other monthly models for the same patient in the same month.
On timing: the earliest meaningful adoption looks like 2026 and beyond, with Medicare defining first and commercial payers following. Local Medicare Administrative Contractors (MACs) will shape enforcement and documentation expectations. The details will come through Physician Fee Schedule rulemaking and sub‑regulatory guidance.
Why behavioral health leaders should care
Behavioral health is a longitudinal workload living inside primary care. When patients are relatively stable—on meds, in therapy, with periodic follow-ups—the work is steady but real. If GPCM follows CMS patterns, it will reward what good behavioral health in primary care requires: measurement, care plans, team-based follow-through, and clear documentation. It will also change your monthly choice set. Some months will fit a general primary care payment. Others will clearly call for Collaborative Care (CoCM) or Behavioral Health Integration (BHI). The key is a simple, defensible way to choose.
What it will likely require (reading CMS’s pattern)
CMS tends to repeat what works. Expect attribution to a named PCP/team and continuity over time. Expect eligibility to hinge on ongoing medical/behavioral complexity that requires between-visit work. Core elements will feel familiar: informed consent, a living care plan, documented team touches, medication and safety monitoring, coordination with specialists (including psychiatry), and patient communication with provenance. Guardrails will likely include defined time or qualifying activities, clear supervision and scope rules, and audit-ready documentation. Coinsurance is likely for Medicare beneficiaries, which means you’ll need to explain value and cost simply and upfront.
How GPCM may interact with BHI, CoCM, CCM, and PCM/APCM
CMS generally prevents overlapping monthly payments for the same work in the same month. Translation: you’ll choose one monthly model per patient per month.
A practical way to think about it:
- Stable behavioral health needs inside general primary care? That’s a GPCM month.
- An active behavioral health episode with a defined care manager and psychiatric consultation? That’s a CoCM month.
- Multiple chronic medical conditions where most of the work is non-BH management? CCM fits.
- A single-condition focus (e.g., post-MI care) with active management? PCM/APCM fits.
What matters is the work you actually plan to do that month and whether your documentation cleanly shows why that model fits.
Hype vs reality
There’s noise out there. “GPCM replaces CoCM/BHI” is unlikely—these models serve different intents. “Free revenue for what you already do” has never been CMS’s posture; auditors will expect countable work tied to a care plan. “AI will unlock GPCM by itself” is wishful; technology helps only when workflows, roles, supervision, and provenance are tight.
What’s real is straightforward: practices with measurement that runs, care plans that live, and orchestration that makes nothing fall through will be ready on day one. Compliance and provenance will matter more than ever. And you’ll need a monthly selection logic you can teach, apply, and defend.
The operational backbone GPCM will reward
Start with a complete intake that seeds a shared care plan—medical and behavioral. Run measurement on autopilot and surface it where clinicians work: PHQ‑9, GAD‑7, vitals, key labs, trends that drive action. Orchestrate the month: who does what, when, and why; escalation rules that are automatic and documented; a steady cadence of patient touches. Capture time and activities in the right month with consent, supervision, and attribution spelled out. Produce clean artifacts—PCP letters, patient education, care manager notes, safety checks—with provenance. This is the same backbone that makes CoCM/CCM clean and defensible. It’s the same backbone GPCM will likely expect.
What to build in the next 90 days
Don’t wait for codes to finalize. Install a monthly selection rubric across GPCM, BHI/CoCM, CCM, and PCM/APCM and train your team to use it. Stand up a “month‑in‑the‑life” cadence—measurement outreach, medication checks, care gap closure, and follow‑ups that are planned, not ad hoc. Create audit‑ready templates for consent, living care plans, time/activities logs, and escalation/supervision notes. Map attribution and stratify panels: who is GPCM‑ready today; who needs CoCM this month. Tighten behavioral health pathways so it’s obvious when to escalate to CoCM versus stay in a general month. Update patient communication so coinsurance is clear and the value of monthly management is obvious. And have your compliance team review MAC guidance and recent denial patterns so reality, not rumor, shapes your build.
Scenarios you’ll see—and how to decide
1. A patient with mild–moderate depression, stable on meds? That’s a GPCM month: track PHQ‑9 monthly, nudge adherence, monitor side effects, coordinate with therapy, and document touches.
2. A new complex episode with suicide risk and medication changes? That’s a CoCM month: define the care manager, add psychiatric consultation, run a stepped plan, review the registry weekly.
3. Multi‑morbidity with a behavioral flare (DM, CHF, GAD)? Decide between CCM, CoCM, and GPCM based on where the majority of work sits this month and which model best reflects it.
4. Psychiatry providing consultative support to PCP? CoCM lives under the PCP; psychiatry bills usual services, not the monthly code.
Risks to manage
Double‑counting across codes is the fastest way to denials. “Ghost work” that isn’t documented won’t count. Supervision gaps and stale care plans erode defensibility. Equity drift—enrolling only easy patients—undercuts the mission and will show up in audits. And coinsurance surprises will backfire unless you explain costs and benefits clearly, early, and in plain language.
How Zenara is preparing practices
In my San Francisco practice, we’ve run clean monthly claims for over a year with policy‑aware guardrails. We make the invisible work visible—measurement, tasks, time, consent, provenance—then choose the right model per patient, per month. It’s the same approach we’re configuring for partner practices now so they can move confidently when GPCM becomes real. I’ve run measurement‑based care for ten years across roughly 400 patients, and what works is consistent: small, evidence‑based workflows, fitted to your reality, produce outsized impact.
What to watch next
Track the Physician Fee Schedule proposed and final rules, the HCPCS/CPT descriptors, and sub‑regulatory guidance. Watch MAC‑level articles and FAQs; they often preview audit posture. Follow commercial payer timelines for adopting any GPCM‑like benefit. And look for explicit stacking guidance across monthly models—this will drive your monthly selection logic.
If you want the monthly selection rubric and “month‑in‑the‑life” cadence installed in your practice, request a practice checkup or join the waitlist. We’ll fit it to your current stack and protect quality as you scale.
Sources & References
Policy trajectory and context
- CMS CY 2025 Medicare Physician Fee Schedule Proposed Rule — Fact Sheet:
https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2025-medicare-physician-fee-schedule-proposed-rule
- CMS CY 2024 Medicare Physician Fee Schedule Final Rule — Fact Sheet:
https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-final-rule
- CMS Innovation Center: Making Care Primary (MCP) Model:
https://innovation.cms.gov/innovation-models/making-care-primary
- MedPAC June 2024 Report to Congress (primary care payment):
https://www.medpac.gov/document/june-2024-report-to-the-congress-medicare-and-the-health-care-delivery-system/
- National Academies: Implementing High-Quality Primary Care (2021):
https://nap.nationalacademies.org/catalog/25983/implementing-high-quality-primary-care-rebuilding-the-foundation-of-health
- CMS Behavioral Health Strategy (2022):
https://www.cms.gov/files/document/cms-behavioral-health-strategy.pdf
Care management precedents and rules
- MLN Booklet: Care Management Services Guide (CCM, BHI, CoCM, PCM):
https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/care-management-services-guide.pdf
- MLN Booklet: Behavioral Health Integration (BHI):
https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/behavioralhealthintegration.pdf
- MLN Booklet: Psychiatric Collaborative Care Model (CoCM):
https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/psychiatric-collaborative-care-model.pdf
- MLN Booklet: Chronic Care Management (CCM):
https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts/downloads/chroniccaremanagement.pdf
- PCM educational materials (CMS):
https://www.cms.gov/medicare/medicare-fee-for-service-payment/physicianfeesched/care-management
- Medicare Claims Processing Manual, Chapter 12:
https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/clm104c12.pdf
MAC-level operational nuance
- Novitas Solutions (Care Management resources):
https://www.novitas-solutions.com
- Noridian Healthcare Solutions (Care Management resources):
https://med.noridianmedicare.com
- Palmetto GBA (Behavioral Health/Care Management):
https://www.palmettogba.com
Clinical model and implementation
- AHRQ Academy: Collaborative Care Model:
https://integrationacademy.ahrq.gov/products/collaborative-care-model
- AHRQ Academy: Behavioral Health Integration Playbook:
https://integrationacademy.ahrq.gov
- APA: Measurement-Based Care in Psychiatry:
https://www.psychiatry.org/psychiatrists/practice/professional-interests/measurement-based-care
Validated instruments
- PHQ‑9 validation: Kroenke K, Spitzer RL, Williams JB. J Gen Intern Med. 2001.
PubMed: https://pubmed.ncbi.nlm.nih.gov/11556941/
Full text: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1495268/
- GAD‑7 validation: Spitzer RL, Kroenke K, Williams JB, Löwe B. Arch Intern Med. 2006.
PubMed: https://pubmed.ncbi.nlm.nih.gov/16717171/
Collaborative care evidence base
- IMPACT Trial (late-life depression): Unützer J et al. JAMA. 2002;288(22):2836–2845.
https://pubmed.ncbi.nlm.nih.gov/12472325/
- Collaborative care meta-analysis: Archer J et al. Cochrane Review. 2012.
https://www.cochranelibrary.com/cdsr/doi/10.1002/14651858.CD006525.pub2/full
Compliance and audit posture
- OIG: Medicare Paid for CCM Services That Did Not Meet Requirements:
https://oig.hhs.gov/oas/reports/region9/91803035.asp
- CMS Program Integrity: Documentation Requirements:
https://www.cms.gov/Medicare/Medicare-Feefor-Service-Compliance/Documentation-Requirements
Patient communication and cost-sharing
- MLN: Beneficiary cost‑sharing basics:
https://www.cms.gov/outreach-and-education/medicare-learning-network-mln/mlnproducts
- AAFP: BHI/CoCM payment guides:
https://www.aafp.org/family-physician/patient-care/care-management/bhi.html
Primary care payment models to benchmark
- Comprehensive Primary Care Plus (CPC+):
https://innovation.cms.gov/innovation-models/comprehensive-primary-care-plus
- Primary Care First (PCF):
https://innovation.cms.gov/innovation-models/primary-care-first-model-options
Regulatory monitoring
- CMS Physician Fee Schedule resources:
https://www.cms.gov/medicare/medicare-fee-for-service-payment/physicianfeesched
- Federal Register — CMS page (subscribe for updates):
https://www.federalregister.gov/agencies/centers-for-medicare-medicaid-services
