Chronic disease prevention and management is taking center stage in the proposed 2025 Physician Fee Schedule (PFS). CMS is asking for broad feedback on how to better support preventive care, lifestyle interventions, and innovative treatment approaches to address chronic conditions. This aligns with the Trump Administration’s “Make America Healthy Again Commission” Executive Order, which directs agencies to focus on lowering chronic disease rates through lifestyle, nutrition, and community-based strategies.
Chronic Disease Prevention Key Context
- Six in ten Americans live with at least one chronic disease.
- Four in ten have two or more chronic diseases.
- Leading causes of these chronic conditions: smoking, poor nutrition, physical inactivity, excessive alcohol use.
- In 2023, 22.8% of adults (58.7 million) had a mental illness.
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Current Medicare Part B preventive services exist but have important restrictions.
- For example, most of the preventive services covered by Medicare are screening services. (See: Medicare Preventive Screening Services. Even if a covered prevention program includes lifestyle education and coaching, it is only after a patient has been determined to be at risk for a certain illness after a screening. See e.g., Medicare Diabetes Prevention Program.)
- For example, most of the preventive services covered by Medicare are screening services. (See: Medicare Preventive Screening Services. Even if a covered prevention program includes lifestyle education and coaching, it is only after a patient has been determined to be at risk for a certain illness after a screening. See e.g., Medicare Diabetes Prevention Program.)
CMS Requests Public Feedback
CMS is soliciting input on:
1. Improving Chronic Disease Prevention & Self-Management
- What services best address root causes of chronic disease?
- How can CMS enhance support for lifestyle and behavioral change?
2. Addressing Social Isolation & Loneliness
- Should there be codes for services tackling social isolation in older adults and Medicare populations?
- What evidence exists for community-based interventions?
3. Physical Activity & Exercise Programs
- Should CMS expand coding/payment for supervised exercise, referrals, and wearable technology integration?
4. New Services Under Consideration
- Intensive Lifestyle Interventions (distinct from existing behavioral therapy codes).
- Medically Tailored Meals (post-hospital discharge, supervised by billing practitioners, or referred to community organizations).
- FDA-Cleared Digital Therapeutics for chronic disease management.
- Motivational Interviewing as a billable, supervised service.
5. Annual Wellness Visit (AWV) Enhancements
- Could optional add-on codes reduce burden and improve uptake?
- Should CMS make AWVs more flexible and patient-centered?
6. Community Partnerships
- Opportunities for coding/payment to support collaborations with Area Agencies on Aging, community hubs, and disability organizations.
Motivational Interviewing & Health Coaching
- CMS highlights evidence that motivational interviewing improves health behaviors (smoking cessation, substance use reduction, increased activity, weight loss, lower blood pressure).
- Considering new codes to support motivational interviewing under general supervision.
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Exploring overlap with health coaching:
- Current Category III CPT codes (0591T, 0592T, 0593T) exist but sunset in 2030.
- Health coaches lack a Medicare benefit category, but could operate under physician supervision.
- CMS requests feedback on training, supervision, certification, and telehealth use for motivational interviewing.
Why This Matters for HR & Wellness Professionals
- Prevention is priority: Employers should align wellness programs with CMS’s push for preventive care.
- Opportunities for integration: Nutrition support, exercise promotion, and motivational interviewing could all receive stronger policy backing.
- Workforce wellness crossover: Many of the same interventions under discussion (tailored meals, lifestyle coaching, digital therapeutics, telehealth) are already central to workplace wellness.
- Future reimbursement potential: Employer-based wellness providers should prepare for services that may soon carry CMS recognition and payment pathways.
Action Steps for Wellness Leaders
1. Engage in CMS’s Public Comment Process
- Add your voice on services like tailored meals, digital therapeutics, and lifestyle interventions.
2. Strengthen Lifestyle & Behavior Programs
- Ensure coaching, exercise, and nutrition programs meet evidence-based standards.
3. Prepare for Motivational Interviewing
- Train staff or partner with certified providers who can integrate motivational interviewing.
4. Explore Community Partnerships
- Collaborate with local aging services, disability groups, and community health hubs.
5. Track Policy Developments
- Monitor coding updates and prepare to integrate new reimbursable services into benefit offerings.
Comments can be submitted to CMS electronically by September 12, 2025 by visiting this website: https://www.regulations.gov/.
Final Word
The 2025 Physician Fee Schedule signals a new era of prevention-first healthcare policy. By focusing on chronic disease prevention, lifestyle interventions, and evidence-based coaching, CMS is inviting input that could reshape both Medicare and employer-sponsored wellness programs. If you need assistance with your wellness practice or program, that’s what Wellness Law, LLC is here for! Contact us today.