PMHNP Noncompete Clauses: 2026 State Law Guide
Six states rewrote healthcare noncompete rules in 12 months. What PMHNPs should check, negotiate, and refuse in a 2026 job contract before they sign it.
Read More →Medicare's Collaborative Care model needs a psychiatric consultant, and most PMHNPs qualify. How the role works, who bills, and how to contract for it.

TL;DR
What this covers
Two to three hours a week. That is how much psychiatric consultant time the University of Washington’s AIMS Center budgets for each full-time care manager in a Collaborative Care program. For most of those hours, the consultant never lays eyes on a patient.
Medicare has paid for this model since 2017. A primary care clinician bills for it, and a behavioral health care manager does the week-to-week follow-up. A psychiatric consultant reviews the whole caseload, spots the patients who aren’t getting better, and recommends the changes the primary care clinician then makes.
The consultant seat is where PMHNPs come in. CMS doesn’t reserve it for psychiatrists. Its January 2026 Behavioral Health Integration booklet defines the psychiatric consultant as a medical provider trained in psychiatry and qualified to prescribe the full range of medications. For a primary care group with no psychiatrist on staff, filling that seat decides whether the program launches at all.
That makes it a career path few new PMHNPs have heard of. It’s part-time and usually remote, paid by contract, and it runs on population-level thinking rather than back-to-back 20-minute med checks. This guide covers what the work involves and who gets paid for what. It also covers how to contract for the role without taking on risk you never priced in.

CMS describes Collaborative Care, or CoCM, as a team of three built around the patient. The treating (billing) practitioner is a physician or nurse practitioner, usually in primary care. The behavioral health care manager has training in social work, nursing, or psychology and follows patients with validated rating scales and a registry. The psychiatric consultant advises both of them.
The consultant’s duties, as CMS lists them, are specific. You review the clinical status of every patient in the program, advise on diagnosis, and suggest fixes for adherence and tolerability problems. You adjust treatment for patients who aren’t progressing and flag interactions between psychiatric and medical treatment.
CMS also spells out what the role usually leaves out. The consultant “isn’t generally expected to have direct patient contact, prescribe medications, or deliver other treatment directly to the patient,” and can be located anywhere. When a patient needs more than the team can offer, the consultant should recommend a referral for direct psychiatric care.
Here is what a typical recommendation looks like. A 42-year-old has been on sertraline 100 mg for eight weeks, and her PHQ-9 has moved from 18 to 15, well short of a 50% response. She reports no side effects. The consultant recommends increasing to 150 mg and repeating the PHQ-9 in four weeks, with a switch or augmentation plan written down in case she still hasn’t responded. The primary care clinician writes the prescription.
An episode of care ends in one of three ways, according to CMS. The patient meets treatment goals, the team refers them for direct psychiatric care, or six consecutive months pass without any CoCM services.

Collaborative Care is a monthly, time-based service, and the minutes that count are the care manager’s. CMS’s January 2026 booklet lists four codes:
CPT time rules apply to all of them. Before any of it starts, the billing practitioner needs a qualifying initiating visit, such as a comprehensive E/M visit or an annual wellness visit. The patient also has to agree to consultation with specialists, including the psychiatric consultant. Verbal consent is fine as long as someone documents it.
Now the part that trips people up. The consultant does not bill any of these codes. CMS says care team members are “either employees or working under contract with the billing practitioner whom Medicare directly pays.” The practice collects the revenue and pays you out of it.
There is one 2026 wrinkle. Practices billing Advanced Primary Care Management can now add G0568 or G0569 for Collaborative Care delivered in the same month, and those add-ons aren’t time-based. The broader APCM changes are covered in Medicare 2026: 4 PFS Changes Every PMHNP Must Know.
Because the codes pay per patient, per month, the consultant’s workload grows with the size of the caseload. That is why the AIMS Center sizes consultant time per care manager, not per clinic.
The systematic caseload review is the center of the job. AIMS describes it as a weekly session between the care manager and the psychiatric consultant, driven by the registry rather than by whoever happens to be on anyone’s mind.
The AIMS Center breaks the 2 to 3 weekly hours into three parts: 30 to 60 minutes of preparation, 60 minutes for the review, and 30 to 60 minutes of documentation and quick consults. Before the meeting, the care manager and the consultant each scan the registry and list the patients they want to discuss. They compare lists at the start and set a shared agenda.
You won’t discuss every patient every week. AIMS is explicit that priority goes to patients who aren’t improving quickly enough or who are diagnostically complex. A patient whose GAD-7 has dropped from 15 to 6 gets a sentence. A patient stuck at a PHQ-9 of 17 after two medication trials gets 10 minutes.
The skills are different from outpatient med management. AIMS lists triaging and treating patients you haven’t seen, building a plan quickly from limited information, and thinking about the needs of a whole population.
“The consultant role rewards a clinician who can look at a PHQ-9 trend, a medication list, and two lines of care manager notes and know which question to ask next. You build that by seeing a lot of patients yourself and having someone check your reasoning. The indirect work sits on top of that foundation.”
— Lindsay Hill, DNP, PMHNP-BC
In practice, each discussed patient ends with a written recommendation the care manager takes back to the primary care clinician. That usually means a dose change, a switch, a lab to order, or a referral out.
Two assumptions keep PMHNPs out of this work, and a third gets the ones who take it into trouble.
The first is that CoCM consulting is a psychiatrist’s job. The CMS definition says trained in psychiatry and qualified to prescribe the full range of medications. It never says physician, and the AIMS Center says the role can be filled by any psychiatric expert.
The second is that Collaborative Care is a pilot-program niche that will fade. The evidence behind it is more than two decades old. The IMPACT trial, published in JAMA in 2002, enrolled 1,801 adults aged 60 and older at 18 primary care clinics. At 12 months, 45% of patients in Collaborative Care had cut their depressive symptoms at least in half, compared with 19% in usual care. Medicare has paid for the model since 2017, and CMS added new CoCM add-on codes for 2026.
The third assumption is the dangerous one: no face-to-face contact means little liability. Your recommendation shapes a prescription for a patient you have never met, based on data someone else collected. The risk doesn’t go away. It moves into your documentation. Every recommendation should name the data it relied on, the date, and what should happen if the plan fails.
Scope matters here too. If your state restricts NP prescribing of certain controlled substances, you may not meet the full-range definition on paper. Check your state against PMHNP Scope of Practice by State: 2026 Full Practice Authority Update before you apply.

Start with the hours math. At the AIMS benchmark, a practice with two full-time care managers needs 4 to 6 consultant hours a week, or about 17 to 26 hours a month. Size the contract to that estimate and write in a review at 90 days, because caseload size can change quickly after launch.
Hourly pay or a monthly retainer tied to expected hours is the simplest structure to run. Before you agree to a per-patient rate or a share of collections, have a healthcare attorney review it, since pay tied to billing brings its own compliance questions. If the role is a 1099 arrangement, the tax math in PMHNP 1099 vs W-2: What the Offer Really Pays applies here too.
Then get the rest of the contract in writing:
For new graduates, the order matters. Build direct-care volume first, then add consulting once you can defend a plan from a chart alone. Structured case review with experienced PMHNPs, the kind built into the Psych NP Fellowship, is the fastest way to develop that judgment.

Yes. CMS defines the psychiatric consultant as a medical provider trained in psychiatry and qualified to prescribe the full range of medications, and a board-certified PMHNP with full prescriptive authority fits that description. If your state limits NP prescribing of certain controlled substances or requires a collaborative agreement, confirm how that affects the role before you sign.
No. The treating (billing) practitioner, usually a primary care physician or nurse practitioner, bills the Collaborative Care codes. The consultant is paid by that practice as an employee or contractor, and Medicare pays the billing practitioner directly.
The University of Washington AIMS Center estimates 2 to 3 hours per week for each full-time behavioral health care manager. That covers 30 to 60 minutes of preparation, a 60-minute caseload review, and 30 to 60 minutes of documentation and follow-up questions. A program with two full-time care managers needs roughly 4 to 6 consultant hours a week.
Usually not. CMS says the consultant isn’t generally expected to have direct patient contact, prescribe medications, or deliver treatment directly to the patient. The consultant should recommend a referral for direct psychiatric care when a patient needs it.
G2214 covers the first 30 minutes of behavioral health care manager time in a month of Collaborative Care. CMS gives the example of a patient who is hospitalized or referred out before the team reaches the minutes needed to bill 99492 or 99493.
Yes. CMS states that the psychiatric consultant can, and typically will, be remotely located. Programs commonly run the weekly caseload review by video or phone, with the consultant working from shared registry access.
Collaborative Care has a job description most PMHNPs already fit and a billing model that pays the practice, not you. It takes 2 to 3 hours a week for each full-time care manager, done remotely, built around a weekly registry review. The clinical skill involved is judgment from data you didn’t collect, and the business skill is a contract that spells out scope, response times, and coverage.
Your next step takes about an hour. Read the CMS Behavioral Health Integration booklet, then call two primary care practices you already refer to and ask whether they offer Collaborative Care. If they don’t, ask what’s stopping them. Often the answer is that they don’t have a psychiatric consultant.
Build the judgment consulting requires
The Psych NP Fellowship is a 12-month clinical mentorship program for new and early-career PMHNPs. Members bring real cases to experienced PMHNPs and learn to reason through them out loud, the same skill a Collaborative Care caseload review runs on.
Billing rules summarized here reflect the CMS Behavioral Health Integration booklet (MLN909432, January 2026). Commercial payers, Medicaid programs, and state scope-of-practice laws can add their own requirements, so confirm yours before you sign a contract.
This content is for educational purposes and does not replace individualized clinical judgment or supervision.
About the author
Lindsay Hill, DNP, PMHNP-BC is the founder of the Psych NP Fellowship, a 12-month clinical mentorship program for new and early-career psychiatric nurse practitioners. She is a published contributor to Psychiatric Times, past President of the Arizona APNA Chapter, and co-founder of the Psych NP Network.
The Psych NP Fellowship Team provides evidence-based clinical content, prescribing insights, and career guidance for new and early-career psychiatric nurse practitioners. Led by Lindsay Hill, DNP, PMHNP-BC, the team is dedicated to bridging the gap between PMHNP education and confident clinical practice.
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