Behavioral health integration outreach guide

A primary care or specialty practice that adds behavioral health integration takes on a new kind of conversation with patients. Medicare pays for two forms of it: the psychiatric collaborative care model, where a care manager and a psychiatric consultant work alongside the treating practitioner, and general behavioral health integration, which uses other care models. Both are monthly services, both need the patient’s consent before they start, and both carry cost sharing. The first conversation about them has to be accurate about who the patient will deal with, what it costs and what the practice can and cannot promise. This guide works through that conversation using the CMS booklet on these services, the Medicare.gov page patients see, and the federal privacy, telephone and advertising rules that apply to the outreach.

Three related topics have their own guides and are not repeated here. Marketing a psychiatric practice, including telehealth prescribing and the Google Ads rules for prescription services, is covered in our psychiatric practice marketing guide. Monthly care coordination for patients with two or more chronic conditions is in our chronic care management guide. Advertising substance use disorder treatment, with its own Google certification, is in our addiction treatment marketing guide. For the Task Force age groups and online self-check wording, see anxiety screening outreach.

This is general information, not legal or medical advice. Sources cited were checked on October 30, 2026: the CMS Medicare Learning Network booklet Behavioral Health Integration Services (MLN909432, January 2026), the Medicare.gov page Behavioral health integration services, 45 CFR 164.501 and 164.508, 42 CFR 2.11 (as amended at 89 FR 12618, February 16, 2024), 47 CFR 64.1200, 42 U.S.C. 1320a-7a, 15 U.S.C. 45 and 52, and the FTC policy statements on deception and advertising substantiation. Billing codes, payment amounts and time thresholds change with each year’s Physician Fee Schedule and are not covered here. Scope of practice for care team members is set state by state.

What behavioral health integration is, in the words CMS uses

The CMS booklet describes behavioral health integration as integrating behavioral health care with other care, including primary care. It says patients may be eligible if they have an identified mental, behavioral or psychiatric health condition, including substance use disorder, and need a behavioral health care assessment, behavioral health care planning and provision of interventions. The condition can be one the patient already has, or one the billing practitioner diagnoses and refines over time. Other chronic or medical conditions the practitioner manages are not an eligibility requirement.

The booklet calls it a monthly, time-based care management service. Before it starts, the patient needs an initiating visit that establishes the relationship with the billing practitioner and makes sure that practitioner assesses the patient. The booklet lists an annual wellness visit, an initial preventive physical exam, a comprehensive evaluation and management visit, and a transitional care management visit as qualifying initiating visits. Physicians of any specialty, physician assistants, nurse practitioners, clinical nurse specialists and certified nurse midwives can bill these services, and the parts the billing practitioner does not personally perform fall under general supervision.

For outreach, two points matter. First, services start only after an initiating visit with the billing practitioner, so the invitation goes to a patient the practice already treats, not to the public at large. Second, the service sits inside the practice the patient already knows. Your materials should say that plainly instead of presenting it as a separate mental health clinic.

Collaborative care or general integration: describe the one you offer

The booklet describes the psychiatric collaborative care model as a team of three: a behavioral health care manager, a psychiatric consultant and the treating, billing practitioner, with the patient as an active member of the care team. The care manager has formal education or specialized training in behavioral health, such as social work, nursing or psychology, and works under the billing practitioner’s oversight. The psychiatric consultant is trained in psychiatry and qualified to prescribe the full range of medications.

The roles are where outreach goes wrong. The booklet says the psychiatric consultant may be remotely located, is not generally expected to have direct patient contact, prescribe medications or deliver other treatment directly to the patient, and can and should offer a referral for direct psychiatric care when clinically indicated. So a line such as “see a psychiatrist without the wait” describes a service the model does not provide. An accurate description is that the patient’s own practitioner and a care manager lead the care, and a psychiatrist reviews the plan with the team.

The booklet also says an episode of collaborative care ends when the patient meets targeted treatment goals, does not meet them and is referred for direct psychiatric care, or has a break of 6 consecutive months without the service. Telling patients up front that the service is a defined episode with goals, and that it can lead to a referral, sets honest expectations.

General behavioral health integration, in the booklet’s words, covers care models other than collaborative care that systematically assess and monitor patients, adjust care plans for patients who are not improving adequately and provide a continuous relationship with an appointed care team member. It may or may not involve a care manager or psychiatric consultant, and the booklet says a practice may not report both forms in the same month for the same patient. If your practice offers general integration without a psychiatric consultant, do not mention one in your materials.

Consent: what the patient must hear before the service starts

The CMS booklet sets out two things the patient must hear before behavioral health integration services begin. The patient must give the billing practitioner permission to consult with relevant specialists, which includes talking with a psychiatric consultant. And the billing practitioner must inform the patient that cost sharing applies for both face-to-face and non-face-to-face services, even if supplemental insurers cover cost sharing.

The booklet says written consent is not required: verbal consent is allowed, and it must be documented in the medical record. A new consent is needed only if the patient changes billing practitioners. The Medicare.gov page patients read says their provider will ask them to sign an agreement to get these services on a monthly basis, so patients may expect a form. A short written agreement that matches what is documented does both jobs.

Build the consent conversation into the outreach script rather than leaving it to chance. The person who makes the invitation should be able to explain the specialist consultation and the cost sharing in plain words, and then record the patient’s answer. A brochure or web page can prepare the patient, but it does not replace the conversation the booklet describes.

Cost wording: say what Medicare.gov says

The Medicare.gov page says that after the Part B deductible, the patient pays 20% of the Medicare-approved amount for behavioral health integration services, and it lists the service as monthly. That rules out “free”, “no cost to you” and “fully covered” in your invitations, ads and web pages. A cost line that follows Medicare.gov might read: “This is a monthly service. Medicare Part B covers it, and after your deductible you pay a share of the cost, as you do for other doctor services. Our billing team can tell you what that means with your coverage.”

Do not offer to waive the patient’s share as a reason to enroll. Under 42 U.S.C. 1320a-7a(a)(5), a person who offers or transfers remuneration to a Medicare or state health care program beneficiary that the person knows or should know is likely to influence the beneficiary to receive covered services from a particular provider is subject to civil monetary penalties. The definition of remuneration in 1320a-7a(i)(6) includes waivers of coinsurance and deductible amounts, with a narrow exception for waivers that are not advertised or offered in a solicitation, are not routine and follow a good faith finding of financial need or failed collection efforts.

Integration starts with a screening. Our guide to depression screening outreach covers how to invite adults and teens to the screening the USPSTF recommends, what a screening page and a reminder can say, and where the 988 and 911 lines belong.

Who makes the outreach and what the time counts for

The booklet lists outreach to and engagement of the patient, directed by the treating practitioner, among the required elements of the first month of collaborative care. It also says the behavioral health care manager role does not include administrative or clerical staff, and that time spent solely on administrative or clerical duties does not count toward the service’s time threshold. The same applies to clinical staff in general integration.

That gives the front desk a clear lane. Scheduling staff can book the initiating visit, send the general description and route questions. The conversation about the patient’s symptoms, the care plan and the consent items belongs with the practitioner or the care manager. Scripts should say so, and an AI front desk should do the same: take the request, give general information and pass the patient to a person, without asking screening questions or offering clinical advice.

Privacy: treatment messages, therapy notes and substance use records

Under the HIPAA Privacy Rule, the definition of marketing in 45 CFR 164.501 leaves out communications for the treatment of an individual by a health care provider, including case management or care coordination, and communications describing a health-related service provided by the covered entity itself. An invitation from your practice to your own patient about your own behavioral health integration service fits those exclusions. They fall away when the practice receives financial remuneration from a third party whose product or service is being described, so read the definition with counsel before any outside company pays in connection with the message.

Two kinds of records need extra care in outreach tools. Psychotherapy notes, as 45 CFR 164.501 defines them, are a mental health professional’s notes on the contents of a counseling session, kept separate from the rest of the record. Under 164.508(a)(2), a covered entity must obtain an authorization for any use or disclosure of psychotherapy notes, with narrow exceptions. Keep them out of reminder systems, call lists and any marketing or messaging tool.

Substance use disorder records can carry a second set of federal rules. 42 CFR 2.11 defines a program as a person, other than a general medical facility, that holds itself out as providing and provides substance use disorder diagnosis, treatment or referral for treatment, or an identified unit or designated staff within a general medical facility that does so. The same section says records a Part 2 program transmits to a provider who is not subject to Part 2 keep their character as Part 2 records in that provider’s hands, though the provider may segregate them. If your practice receives records from a substance use disorder program, keep them out of outreach lists and settle with counsel how Part 2 applies before using them for anything beyond treatment.

The patient registry the collaborative care model uses is a clinical tool for tracking follow-up and progress. Treat it that way. It is not a list to market other services from.

Calls, texts and portal messages

The Telephone Consumer Protection Act rules at 47 CFR 64.1200 set the limits for automated calls and texts. Under 64.1200(a)(1)(iii), a call to a cell phone using an automatic telephone dialing system or an artificial or prerecorded voice needs the called party’s prior express consent unless it is made for emergency purposes. Under 64.1200(a)(2), an automated call that includes an advertisement or constitutes telemarketing needs prior express written consent, except for a call that delivers a health care message made by or on behalf of a HIPAA covered entity or its business associate. Whether an invitation is a health care message or an advertisement depends on what it says, so settle that with counsel before you automate it.

Content matters as much as consent here. A text or voicemail that names a depression or anxiety program can be read by whoever sees the phone. A neutral message that asks the patient to call the practice or check the portal protects the patient and still does the job. Our guide to text message appointment reminders covers wording and opt-outs in more detail.

Crisis lines in every channel

The CMS booklet itself points patients to 988: it says anyone experiencing a mental health crisis, including a substance use crisis or thoughts of suicide, can get confidential support 24/7 by calling 988 or visiting 988lifeline.org. Outreach for behavioral health services reaches people who may be struggling, so every channel that invites a reply should say what to do in a crisis.

Web pages and forms about the service: a visible line with 988 and 911, and a note that the form is not monitored for emergencies.
Texts and portal messages: a line that these messages are not monitored for emergencies, with 988 and 911.
Phone scripts and after-hours lines: a step that gives 988 and 911 to anyone who describes a crisis, before anything else.
AI front desk tools: the same step, and no attempt to assess or counsel the caller.

Claims about results

The CMS booklet calls behavioral health integration an effective strategy to improve mental, behavioral or psychiatric health. That is CMS describing a model in general, not evidence of what your practice achieves. Under 15 U.S.C. 45 and 52, and the FTC’s policy statement on deception, an ad is judged by the net impression it leaves on a reasonable consumer, and under the FTC’s policy statement on substantiation, you need a reasonable basis for objective claims before you make them. Claims such as “get relief in weeks”, “proven to reduce depression” or remission figures from your own registry need that basis, and outcome promises about a mental health condition are not something an invitation should make.

Describe the service instead: who is on the team, when the care manager checks in, how the plan is reviewed and changed, what it costs and how to stop. Patient stories and reviews about mental health care raise authorization and typicality questions covered in our psychiatric practice guide.

Illustration: two ways to invite a patient

Illustration: a primary care practice launches collaborative care and sends a text to every patient with a depression diagnosis in the chart: “New! See a psychiatrist through our office at no cost. Feel better fast. Reply YES.” The text names the condition on the lock screen, describes direct psychiatric visits the model does not provide, claims no cost when coinsurance applies after the deductible, promises an outcome and gives no crisis line.

Illustration: the same practice raises the service at visits instead. The practitioner explains it during an eligible visit, and the care manager follows up by phone, explains that a psychiatric consultant will review the plan with the team, says that cost sharing applies each month even with supplemental coverage, records the patient’s verbal consent and sends a neutral portal message with the care manager’s name, how to stop the service and the 988 and 911 line.

Checklist

Materials describe the form of integration you actually offer, and name a psychiatric consultant only if one is on the team.
No promise of direct psychiatrist visits where the consultant reviews plans with the team.
Invitations go to your own patients, and services start only after an initiating visit with the billing practitioner.
The consent conversation covers specialist consultation and monthly cost sharing, and the answer is documented.
Cost wording follows Medicare.gov; no “free”, “no cost” or “fully covered”, and no advertised waivers.
Clinical conversations sit with the practitioner or care manager; the front desk and any AI front desk only schedule and route.
Psychotherapy notes and Part 2 records stay out of outreach and messaging tools.
Texts and voicemails do not name the condition or the program.
Every channel that invites a reply gives 988 and 911 and says it is not monitored for emergencies.
No outcome, remission or speed claims without a reasonable basis, and no outcome promises.

Screening adults for unhealthy drug use, SBIRT and private reminders are covered in our guide to drug use screening outreach.

How we help

We build websites, local search, Google Ads and AI front desk tools for independent practices and health businesses. For a practice adding behavioral health integration, that means a website page that describes the team and costs the way CMS and Medicare.gov do, scripts that put the consent items and crisis lines in the right places, and inquiry flows that send clinical questions to the care team and cost questions to billing. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it. We are not a healthcare provider and we do not give legal or medical advice. We do not sell lead lists and we do not pay for referrals. For the wider rules, see our healthcare marketing rules hub.

Does the patient have to sign a consent form?

The CMS booklet says written consent is not required. Verbal consent is allowed and must be documented in the medical record. The Medicare.gov page tells patients their provider will ask them to sign an agreement, so a short written agreement that matches the record is a reasonable choice.

What must the patient be told before services start?

The booklet says the patient must give permission to consult with relevant specialists, including a psychiatric consultant, and must be told that cost sharing applies for face-to-face and non-face-to-face services, even if supplemental insurers cover cost sharing.

Will the patient see a psychiatrist?

Not as part of collaborative care itself. The booklet says the psychiatric consultant is not generally expected to have direct patient contact or prescribe directly, and should offer a referral for direct psychiatric care when clinically indicated.

Can we say the service is free for Medicare patients?

No. The Medicare.gov page says that after the Part B deductible the patient pays 20% of the Medicare-approved amount, and the service is monthly.

Is an invitation to our own patients HIPAA marketing?

Under 45 CFR 164.501, communications for treatment, case management or care coordination, and descriptions of the practice’s own health-related services, are not marketing unless a third party pays the practice in connection with the message.

Should we list a crisis line in our outreach?

Yes. The CMS booklet points people in a mental health crisis to 988, available 24/7. Give 988 and 911 in every channel that invites a reply, and say the channel is not monitored for emergencies.

Sources

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