CoCM and Medical Necessity

Nicoletti Notes April 2026
Published on April 14th, 2026

Let me start with two pieces of advice:

• Don’t post coding questions that will raise compliance eyebrows on message boards.
• Don’t respond to postings with capital letters or the word “fraud.”

Here are the posts in question. The original post was deleted moments later, after the poster saw the responses.

I am a chronic care manager and I’m having trouble coming up with activities to do for billing on the CoCM side. I talk to the patient and document. That takes about 35 minutes. After that, I research the education for the next call. I’ll research education to provide via email and send the email. I also do medication reconciliation. Sometimes, I get lucky and there will be a document from a specialist to review. Any ideas for other activities to bill? We have 180 minutes to bill for CoCM and sometimes it just doesn’t take that much time. Help is great appreciated.

Response one: If there isn’t any work that NEEDS to be done, what is the medical necessity for finding work? Don’t do it.

Response two:  Fraud.

Chronic care management (CCM) is a service that helps patients with chronic diseases manage their conditions. CCM is usually performed by a care team in a primary care practice.  Psychiatric Collaborative Care Management Services (CoCM) are provided to patients with a behavioral health condition, billed by a primary care practice for work done by a behavioral health manager in collaboration with a psychiatric consultant.

The negative response to the care manager’s question arises from the idea that the practice or vendor that is performing the service for the practice is “entitled” to a certain number of minutes/amount of revenue for every patient every month.

• All services must be medically necessary
• Services that require a certain number of minutes in a calendar month or 30-day period may only be reported when that number of minutes is met with medically necessary service
• Don’t go looking for work to meet the time frame
• Don’t think that all patients should have a certain number of minutes each month; patients’ needs vary
• Just because a patient needs 60 minutes one month doesn’t meant they will need 60 minutes every month
• Just think what our response would be if a physician said, “Well, I just need 5 more minutes to meet the threshold for critical care, how can I fill the time?” We’d all be howling!

Take these actions today:

1. Check your messaging to your internal care managers or vendors; reinforce the medical necessity mandate for all services.
2. Look at your claims. If every patient, every month gets the same and highest number of minutes billed, look carefully.

If you or your vendor are providing CCM or CoCM, don’t look for work. Perform the services needed by the patient.