THANK YOU: 61 Organizations Join Comment Letter Supporting Proposed Medicare Health Coaching Benefit

The Partnership submitted our comment letter responding to CMS on the CY 2027 Medicare Physician Fee Schedule (PFS) supporting proposed Medicare health and well-being coaching benefits!

A sincere THANK YOU to the 61 organizations across the country that joined our sign-on letter, as well as the many partners who used our template language to submit individual organizational comments. By coming together, our network has ensured that the real-world experience of community provider organizations is firmly on the record to help shape a sustainable benefit for health and well-being coaching.

READ THE SUBMITTED COMMENTS - Download the final Partnership comment letter (PDF)

BACKGROUND:

What CMS proposed. The CY 2027 Medicare PFS proposed rule (CMS-1848-P) would establish a Medicare Part B payment for health and well-being coaching under CPT codes 0591T, 0592T, and 0593T, and would recognize training received through Older Americans Act Title III-D evidence-based programs as a qualifying credential for the staff who furnish it. This is the first Medicare payment pathway built for the community-based workforce that already delivers CDSMP, DSMP, Stepping On, EnhanceFitness, and similar programs.

Why it matters. OAA Title III-D delivery has limited formula-grant funding: ACL grantees reached roughly 176,000 participants nationally between 2016 and 2022, a small fraction of Medicare beneficiaries living with multiple chronic conditions. A Medicare Part B pathway is the first mechanism that could enable program delivery scale to need rather than to the grant.

OUR RECOMMENDATION TO CMS:

The Partnership's final comment letter outlined six key recommendations for CMS:

1. Establish general supervision as the supervision standard for the health coaching codes.
2. Confirm that fidelity-bound OAA Title III-D group workshops are billable group health coaching services under CPT 0593T.
3. Defer to ACL to define training completion and maintain the qualifying program roster.
4. Defer to ACL to issue braided funding and non-duplication guidance, concurrent with the final rule.
5. Move to permanent codes while holding the proposed valuation intact.
6. Require an explicit valuation commitment if CMS substitutes G-codes, so the change is valuation-neutral on its face.

ADDITIONAL RESOURCES:

• Final Partnership letter responding to CMS CY2026 PFS Proposed Rule (PDF)
• Template language provided by the Partnership (Word version for download)
• Comment Letter from Freedmen's Health Consulting
• August 2026 Partnership Webinar and Resources

If you have any questions regarding this response or the Partnership's policy work, reach out to Autumn Campbell (acampbell@partnership2acc.org) and Jeremiah Silguero (jsilguero@partnership2acc.org).  

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