No. Although there is no requirement for a behavioral healthcare provider to be physically in the practice’s office, the behavioral healthcare provider must have at least partial access to the practice’s systems. Although the arrangements mentioned meet the intent of CC 09 (maintaining agreements with behavioral healthcare providers), they do not meet the requirements for this criterion.
If a practice site in an organization has integrated behavioral healthcare, the other sites in the organization may receive credit if there is also a process for their patients to access those behavioral healthcare services.
PCMH 2017