A practice document · National model, Michigan notes · twelve pages · CMS MLN909432 · sources checked August 2026
The BHCM Pivot Playbook
Could a limited-license clinician already on your team serve in a different role inside integrated medical care? Collaborative Care creates a behavioral health care manager role that is different from psychotherapy: following patients between medical visits, tracking symptoms, coordinating care, and working with the medical provider and psychiatric consultant. The Playbook shows what would have to change for that role to work.
No form between you and the document. It is yours either way.
Written from the primary sources and the Behavioral Health Workforce Observatory’s records.
Inside
The role
what a behavioral health care manager actually does
The team
medical provider, care manager, psychiatric consultant
The month
what happens between visits, and what work is tracked
The billing structure
who bills the service, and what the codes represent
Two kinds of supervision
psychiatric consultation and licensure, kept separate
The Michigan payer layer
what BCBSM and BCN recognize, and where PGIP fits
The economics
when existing staff changes the calculation
The open hours question
whether qualifying care-manager work counts toward Michigan’s required supervised experience remains unresolved
Sources
CMS guidance, payer materials, Michigan rules, dated
Figure 01
Same clinician. A different clinical role.
What the work becomes, and what the practice bills for it.
Current therapy role
- Psychotherapy
- Visit-based service
- Reimbursement follows the payer’s rules for that clinician’s license
Possible care-manager role
- Follow-up between visits
- Symptom measurement
- Brief interventions appropriate to the role
- Coordination inside the Collaborative Care team
- Qualifying care-management work contributes to the monthly Collaborative Care service billed by the medical practitioner
The clinician did not become more qualified because the billing changed. The job being performed changed.
Collaborative Care is not a way to rebill psychotherapy. The clinician must actually perform the care-manager role, and the whole arrangement must meet the requirements of the model and the payer.
A Michigan note · BCBSM + BCN
What BCBSM and BCN recognize in Michigan.
BCBSM and BCN recognize the Collaborative Care and general behavioral health integration codes, and BCBSM follows the Collaborative Care model described in CMS booklet MLN909432.
Under the model those services are billed by the treating medical provider rather than by the clinician furnishing the care-management work, which is why the question of who may serve as the behavioral health care manager is answered by the model requirements and the payer’s own published rules rather than by the clinician’s billing status alone.
That does not establish that every limited-license clinician, or every staffing arrangement, qualifies. The clinician still has to perform the actual care-manager role, and the arrangement must satisfy the applicable CMS, scope, supervision, documentation, employer or contracting, and payer requirements. Confirm the proposed structure with the payer or Physician Organization before implementing it.
Code recognition and PGIP participation are separate.
Blue Cross’s Collaborative Care PGIP support is limited to primary care and OB/GYN providers, and is implemented with practices through participating Physician Organizations. Detailed program materials are distributed through those organizations, so a practice asks its own PO about participation requirements.
Two kinds of oversight. Do not confuse them.
Psychiatric consultant
Part of the Collaborative Care model. Reviews the caseload and makes treatment recommendations to the medical team.
Licensure supervisor
Supervises a limited-license clinician’s professional practice under Michigan licensing requirements.
They solve different problems. One does not replace the other.
Open question
Whether qualifying care-manager work can count toward Michigan’s required supervised experience remains unresolved. The supervision study asks the question directly. Michigan separately regulates who may supervise, and the training that role requires; the Supervisor Eligibility Checker walks through those requirements and names what the state has not resolved.
The economics
Existing staff changes the question. It does not answer it.
A practice hiring an entirely new care-management team has one cost structure. A practice that already employs a clinician who could appropriately fill the care-manager role may have another.
The calculation involves more than comparing therapy revenue with Collaborative Care revenue. It includes the clinician’s available time, the work the new role requires, psychiatric consultation, medical-provider participation, registry and administrative work, payer rates, and the number of enrolled patients.
The Playbook shows what a practice needs to calculate. It does not promise the answer will be yes.
Related research · The practice study
What happens when a reimbursement pathway changes but the payroll does not?
The Observatory is measuring what Michigan practices are doing with limited-license positions: hours affected, hiring decisions, supervision capacity, and whether a different role inside integrated care could be workable.
About ten minutes · findings go to respondents first