Center for
Integrative Neuroscience

Research · The practice study

Reimbursement rules differ by state and payer. This first wave is fielded in Michigan, and the same study travels to other states from there.

The billing changed. The payroll did not.

Practices are facing a new problem: clinicians they need, patients who need care, and fewer reimbursement pathways for the work those clinicians currently do. A limited-license clinician may be fully trained and still completing the supervised experience required for full licensure. They see clients, carry caseloads, and document their work.

The practice still carries the payroll. The billing pathway may no longer carry the work.

There may be a different role for some of that clinical capacity. The playbook comes first; the research questions come after it.

The BHCM Pivot Playbook A different role for limited-license clinicians inside Collaborative Care

The role · the team · the month · the rules
Two kinds of supervision · the open hours question

CMS MLN909432 cited · Verified August 2026

The BHCM Pivot Playbook shown as a printed implementation guide, an on-screen guide, an at-a-glance roadmap, and four printable card sets: the role, the team, the month, and the rules.
The photograph shows the wider body of work on the care-manager role. The Playbook is the part the Center gives unconditionally.

Complimentary from the Center

Written for the owner doing this arithmetic at the kitchen table.

The role
What is the job, and where are its boundaries?
The team
Who else has to be involved?
The month
How is the work tracked and coded?
The rules
What does each payer require?
Source notes
Where did this come from?

Open the playbook →

No form between you and the playbook. It is yours either way.

The BHCM Pivot Playbook is complete on its own. It answers one bounded question: what the care-manager role is, what it requires, and what remains unresolved. It is not a sample of something else.

Role design, workflow build-out, documentation and payer-specific implementation are a larger kit, and a different problem. Public guidance can explain a rule. Your state, licenses, payers, contracts and staffing decide what applies to you. Kedge Marketplace is where that individualized question gets answered: whether your own payer mix, licenses, contracts, and staffing can support the model, and what it would take.

Figure 01

Same clinician. Different role.

The care-manager role is a different clinical job inside a different care model. Relabeling therapy does not create it.

Current therapy role

  • Individual therapy
  • Visit-based work
  • Counselor treatment record
  • Paid under the applicable therapy billing rules

Possible care manager role

  • Patient follow-up between visits
  • Symptom tracking
  • Brief interventions
  • Care coordination
  • Psychiatric case review
  • Minutes tracked across the month

Collaborative Care

The medical practice bills the qualifying monthly Collaborative Care service when all of the model’s requirements are met.

The clinician’s training did not disappear. The job being done changed.

CMS describes Collaborative Care as a defined team arrangement with specific service components and care-team roles, not a billing alternative for individual therapy.

Center for Integrative Neuroscience · CMS MLN909432 · The practice study

Five things the model requires.

The model is not a switch a practice can flip alone. All five have to be true at once, and the playbook is honest about each of them.

The clinician
Can this person appropriately do the care manager job?
The medical partner
Is there a medical provider responsible for the patient’s medical care and billing?
Psychiatric consultation
Is a qualified psychiatric specialist available to review the patient list?
Patient tracking
Can the team track progress, minutes, and follow-up?
Payer rules
Does the insurer recognize the model, and what does it require?

If you are carrying several of them

The panel is what changes the arithmetic, not the number of clinicians.

A Collaborative Care team is paid monthly for the patients it follows, not per clinician. One care manager can carry a substantial panel, so a practice with several affected clinicians is usually deciding how many panels it can staff and fill, not whether each salary is covered on its own. The first months cost money while the panel builds. What the arithmetic looks like at maturity depends on the panel, the payer mix, and what those clinicians are generating today.

The playbook works the arithmetic through with the published thresholds. The worked example shows the shape of the ramp.

Where a practice starts

01 · Name the billing provider
Which medical provider is responsible for these patients and will bill the monthly service.
02 · Choose the first patients
A small starting group, so the workflow is learned before the panel grows.
03 · Set up the tracking
Somewhere the team records symptom scores, follow-up, and minutes across the month.

Then psychiatric consultation and the payer confirmations, both of which the playbook covers.

This is not a billing workaround. Collaborative Care is a defined arrangement with published requirements in CMS booklet MLN909432, and the playbook shows the requirements rather than a way around them. It is written to be read by the person who signs off on compliance.

This is a model to evaluate, not a recommendation to convert every clinician.

Some practices will have the right medical partner, patient population, workforce, and payer mix. Others will not. The playbook is meant to help owners find that out before they reorganize anything.

An open question

Do care management hours count toward supervised experience?

A limited-license clinician is working toward full licensure, and Michigan requires supervised experience to get there. Whether qualifying work performed as a Collaborative Care behavioral health care manager counts toward those hours remains an open question Michigan should answer.

The playbook does not pretend the answer is settled.

It matters for the practice as well as the clinician: a role that does not count could slow someone’s path to full licensure. The policy work to seek a clear answer belongs with the Integral Neuroscience Initiative.

The exchange · about ten minutes

Ten minutes, if the playbook earned them.

We already have evidence that Michigan practices are changing hiring decisions as reimbursement rules change. What we do not yet know is the operational detail behind those decisions.

How many limited-license clinicians are affected? How many clinical hours are becoming harder to reimburse? What are owners doing with those positions? Could a care manager role preserve some of that workforce, and what would make the idea impossible? About ten minutes of your experience helps answer those questions. This is the longest of the six studies, because the practice side has the most moving parts. Findings go to respondents first.

If the playbook is useful, send it to whoever runs your billing. Most of the questions it answers land on their desk first.

About 10 minutes

Who you employ · hours at risk · hiring decisions · supervision capacity · whether a care manager role could work here · what would make it unworkable

The survey

The study is not collecting responses yet.

When it opens, the invitation you received will return you to this page. The playbook above is complete and yours to use now.

In the meantime, two things you can do now. Ask to be told when it opens, or ask for the findings without answering anything at all.

At the end, three permissions are asked separately: whether we may follow up, whether we may quote you anonymously, and whether you want the findings. None is required. You will see any proposed quote before we use it.