Several health and wellness coaches have inquired lately as to whether they can bill Medicare for their services. There is buzz within the coaching community that Medicare may now allow coaches to bill the program for services delivered to Medicare beneficiaries. The answer is a bit complicated. In short, state-licensed health care professionals who offer health and wellness coaching could bill Medicare for those services, assuming all the billing requirements are met. Coaches who are not licensed by a state licensing board for an officially recognized health profession (such as medicine or nursing) would NOT be able to bill Medicare, as explained below.
The “buzz” about Medicare paying for health and wellness coaching derives from the most recent Medicare Physician Fee Schedule. In the 2024 Physician Fee Schedule, the Centers for Medicare and Medicaid Services (CMS) included in the Medicare Telehealth Services List the following Current Procedural Technology (CPT) codes.
- CPT code 0591T (Health and wellbeing coaching face-to-face; individual, initial assessment)
- CPT code 0592T (health and wellbeing coaching facet-to-face; individual, follow-up session, at least 30 minutes); and
- CPT code 0593T (Health and wellbeing coaching face-to-face group (2 or more individuals), at least 30 minutes).
88 Fed. Reg. at 78859 (Nov. 16, 2023). CMS did not make these CPT codes for Medicare Telehealth Services permanent; they are only temporary because CMS states it needs more evidence that these services offer a clinical benefit when delivered directly by or under the supervision of the “types of professionals who are Medicare telehealth practitioners.” Id. Thus far, according to CMS, the benefit of health and wellness coaching services has been “anecdotal” and not from peer-reviewed literature. Id. at 78860. CMS would like to see more scientific studies involving health and wellness coaching where the study population is typical of the Medicare population and the methods focus on evaluating utilization and outcomes. Id.
Regardless of whether the CPT codes for telehealth health and wellness coaching services become permanent, the more pressing question is who can bill Medicare for those services? The answer is found in Social Security Act § 1834(m), which states the following (in relevant part):
Payment for Telehealth Services.—
(1) In general.—The Secretary shall pay for telehealth services that are furnished via a telecommunications system by a physician (as defined in section 1861(r)) or a practitioner (described in section 1842(b)(18)(C)) to an eligible telehealth individual enrolled under this part notwithstanding that the individual physician or practitioner providing the telehealth service is not at the same location as the beneficiary.
SSA § 1834(m)(4)(E). Thus, under the Medicare statute, physicians or “practitioners” can bill Medicare for telehealth services. The Medicare statues define “practitioners” as:
- Physician assistants, nurse practitioners, or clinical nurse specialists
- Certified registered nurse anesthetist
- Clinical social worker
- Clinical psychologist
- Registered dietitian or nutrition professional
SSA § 1842(b)(18)(C).
Of course, the COVID19 pandemic expanded the types of “practitioners” who can bill Medicare for telehealth services to include qualified occupational therapists, physical therapists, speech-language pathologists, and audiologists, as well as marriage family therapists and mental health counselors. 88 Fed. Reg. at 78874 (Nov. 16, 2023).
What these laws mean is that only licensed health care professionals can bill Medicare for the telehealth health and wellness coaching services. This conclusion is further supported by Chapter 12, Section 190.6 of the Medicare Claims Processing Manual, which states that the only practitioners who can receive payment for Medicare telehealth services are those who are “licensed under state law to provide a covered telehealth service.”
Health and wellness coaches who do not also have a state-issued license for a recognized health profession are not eligible to receive payment from Medicare for health and wellness coaching services. They could, however, possibly work with a licensed physician or practitioner who could bill for coaching services on their behalf. Those coaches who are licensed by a state for practicing a recognized health profession could bill Medicare for coaching services if they were providing those services as a licensed professional. Thus, those licensed health professional coaches would need to restrict their services to states in which they held a license.
This is a lot to digest, but Wellness Law is here to help. Please contact us today to schedule a consult with us.