Medicare Is Ready to Pay for Coaching. The Details Will Decide Whether It Works. It's Your Moment to Help.
Comments to CMS close September 14, 2026
On July 16, the Centers for Medicare & Medicaid Services (CMS) proposed what Wellcoaches has worked toward for twenty-five years: national Medicare payment for health and well-being coaching. CMS proposed national payment of three coaching codes — 0591T, 0592T and 0593T — available to Medicare beneficiaries across the country. This CMS move sets the stage for wider payment for coaching services beyond Medicare in the future.
We are halfway there, and we will get the rest of the way with wide comments from a multitude of coaches, physicians/clinicians, and organizations.
What Works
The CMS proposal accomplishes several important things:
1. It establishes national payment rather than leaving these codes to be priced Medicare contractor by contractor, which has not occurred since the coaching codes were added to the Medicare telehealth list in 2024.
2. It values coaching against chronic care management, which is a good comparison — both are longitudinal, both are delivered by trained clinical staff, both support patients in the long stretches between office visits.
3. It keeps coaching on the Medicare Telehealth Services List, including audio-only delivery where permitted, which matters everywhere, but particularly for rural and homebound beneficiaries.
4. It recognizes that coaches employed by community-based organizations can furnish these services.
5. CMS declines to impose frequency limits, leaving the number of sessions to medical necessity rather than an arbitrary cap.
6. CMS adopts the CPT definition of what coaching that we (NBHWC and VA) established with the AMA CPT Panel: a patient-centered approach in which patients determine their own goals, use self-discovery and active learning, and self-monitor their behavior, all within a relationship with a coach.
What We Are Asking CMS to Do
Our comment letter makes six requests:
1. Replace the temporary Category III codes with permanent G-codes to indicate long-term commitment and update descriptors to state clearly what the service is and how much qualified professional coach time it requires.
2. Pro-rate the practice expense to the clinical labor time in each descriptor, so that sixty minute coaching sessions are paid as sixty minutes of clinical work, and thirty minute coaching sessions are paid as thirty minutes of clinical work.
3. Confirm that these services are furnished under general supervision, which is currently the standard of care.
4. Maintain the coach certification standard exactly as the codes already define it (created by NBHWC and AMA CPT Panel in 2021), as a condition of payment.
5. Direct the valuation of evidence-based education programs funded under the Older Americans Act to the diabetes self-management training codes, G0108 and G0109, which are built for accredited curriculum-based programs. While those programs are valuable; they are not the patient-directed service the coaching codes describe.
6. Extend the delivery-organization provision beyond community-based organizations to hospital outpatient departments, rural health clinics and federally qualified health centers.
Why Your Comments Matter
Wellcoaches is submitting detailed comments on coaching services for Medicare beneficiaries along with NBHWC and other organizations. Your own story as a coach or physician matters now to CMS, which reads every comment.
How to Comment Before September 14
To get the full picture, here is a PPT summary of our requests and our draft comments:
Download PPT overview
Download draft comments
We prepared two short guides - one for physicians and other billing practitioners, one for certified coaches:
Download the guide for physicians
Download the guide for coaches
QUICK INSTRUCTIONS to SUBMIT CMS COMMENTS:
1. Go to this link: https://www.regulations.gov/docket/CMS-2026-2377
2. Click Comment.
3. For: What is your comment about? Select your professional type from dropdown.
4. Paste your comment into the box, or attach it as a PDF or Word file.
5. Submit before the comment period closes at 11:59 pm ET, September 14, 2026.
Your comment becomes part of the permanent public record, including your name and everything you write.
Comments close at 11:59 PM ET September 14, 2026. Don't miss the deadline!
Wellcoaches Corporation has trained more than 16,000 health and wellness professionals over 25 years, co-founded(2010) and co-created (2010-2023) the National Board for Health and Wellness Coaching and its national training standards, coaching competencies, and certification examination.
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