APCM Compliance Checklist for Depression & Anxiety BHI

Ensure the EHR contains a timestamped record of the patient's agreement to APCM and BHI services, including cost-sharing explanations.

Confirm patients have two or more chronic conditions, with depression or anxiety documented as a primary focus for BHI add-ons.

Use AI call handling to reach out to eligible patients, explain the program, and capture initial verbal intent for clinical follow-up.

Document how patients can access care teams 24/7, a core APCM requirement managed via automated after-hours AI triage.

Cross-reference APCM enrollment with the most recent AWV to ensure the initiating visit requirement is satisfied and billed correctly.

Establish a schedule for monthly or quarterly screenings to track symptom severity and meet BHI quality measure requirements.

Deploy AI voice agents to call patients and prompt completion of digital PHQ-9/GAD-7 forms prior to medication management visits.

Ensure any 'positive' response to PHQ-9 Question 9 triggers an immediate, documented clinical protocol and provider notification.

Document monthly check-ins regarding antidepressant or anxiolytic adherence, side effects, and pharmacy refill status.

Maintain a registry of patients not responding to two or more medication trials to justify higher-level BHI intervention codes.

Maintain precise logs of non-face-to-face time spent on behavioral health integration activities, meeting the 20-minute threshold.

Document communication between the primary care provider and the psychiatric consultant or behavioral health manager.

Keep minutes or EHR notes from weekly systematic case reviews where the patient's mental health progress was discussed.

Sync AI-handled patient check-in logs directly to the EHR to count toward monthly clinical staff time requirements.

Document barriers to mental health care, such as transportation or financial issues, as part of the comprehensive BHI care plan.