Public comment open · closes September 14, 2026
Medicare is one step from paying for Nurse Coaching.
CMS/Medicare has proposed covering Health and Wellbeing Coaching – and named AHNCC NC-BC board certification by name.
What the proposal doesn’t yet recognize is that a licensed nurse doesn’t need supervision to teach, counsel, and guide a patient toward lasting change. CMS is asking for comment. We have until September 14 to answer.
Comment deadline
September 14, 2026
11:59 p.m. ET
File code
CMS-1848-P
Reference this on every comment
Codes proposed
0591T, 0592T, 0593T
Individual, follow-up, and group coaching
What CMS proposed
Recognition, and a payment mechanism
In the CY 2027 Physician Fee Schedule proposed rule, CMS proposed national payment for health and well-being coaching — an initial assessment, follow-up sessions, and group coaching — with no frequency limits. It also named the American Holistic Nurses Credentialing Corporation standards for Certified Nurse Coaches among the accepted certifications.
That recognition did not appear by accident. It is there because Nurse Coaches like you used their voice during the last comment cycle — describing their practice, their patients, and what changed for them — and CMS listened. The same opportunity is open again, and it closes in weeks.
What remains unresolved
A condition of payment that does not fit licensed nurses
The proposal treats everyone furnishing these services as auxiliary personnel working under the direct supervision of a billing practitioner. That framing fits a coach whose only accountability is a certificate. It does not fit a Registered Nurse or Advanced Practice Registered Nurse holding an independent state license.
Health promotion, patient education, and behavior-change counseling are already independent functions of nursing under every state nurse practice act. No state requires supervision to provide them.
Exhibit — 91 FR 43842, section II.D.3.c.(56)
… we are proposing to crosswalk work and direct PE inputs for 0591T and 0592T to CPT codes 99490 and 99439… since, like Chronic Care Management, these visit-based services are performed under general supervision.
CMS established the valuation for these codes by reference to services it describes as furnished under general supervision, then proposed direct supervision as the condition of payment. The valuation and the condition rest on contradictory premises — the most substantive point a comment can raise.
Three concerns
Why the supervision condition warrants revision
Licensure
It duplicates oversight that already exists
Nurses answer to a state board with continuing-education and disciplinary authority. Board certification adds a national examination and supervised practice hours on top. Supervision adds a scheduling constraint, not a safeguard.
Setting
It applies a stricter standard to the more credentialed professional
The same rule would permit a coach employed by a community-based organization to work under general supervision. A board-certified nurse in a clinic would not. Employment setting, rather than licensure, would determine the level of oversight.
Access
It concentrates care where care is already available
Since January 2026, direct supervision may be satisfied by real-time video — but a practitioner must still be available for the whole session. Group coaching becomes difficult to schedule, and sites without steady practitioner coverage go without.
The requests, in order
What to tell CMS
These four requests appear in the same order in every template. Consistency across many individually written letters is what an agency registers.
1
Finalize the payment
Adopt national payment for 0591T, 0592T, and 0593T as proposed, including the valuations and the absence of frequency limits.
2
Remove the supervision condition for licensed nurses
For RNs and APRNs holding AHNCC board certification, defer to state licensure and scope-of-practice law instead.
3
If a condition is retained, apply general supervision
Consistent with the chronic care management crosswalk CMS used to price these codes, and with the treatment of coaches employed by community-based organizations.
4
Name Nurse Coaches, and establish a billing pathway
List AHNCC board-certified Nurse Coaches among qualified personnel, and if CMS creates G-codes for CY 2027, build a route for licensed Nurse Coaches to furnish and bill directly.
Downloadable Templates
Start from a template
Each template is editable, with highlighted fields to personalize.
CMS discourages duplicative comments, so the opening, the closing, and your patient example should be written in your own words.
RN / APRN
Individual comment
One page, plus optional arguments to swap in and a submission checklist.
Association
Nursing organization comment
For associations, credentialing bodies, and schools of nursing. Includes full talking points.
Employer / Clinics
Practice or health system comment
For clinics, FQHCs, and systems that employ Nurse Coaches. Built around operational detail.
Share
Action alert one-pager
Forward to colleagues, chapters, and employers. Everything on one page.
Filing
How to submit
01
Write it in your own words
Revise the opening and closing at minimum. A letter written in your own voice carries considerably more weight than identical text submitted many times over.
02
Add one patient story
Three to six sentences: the chronic condition, the behavior change, the outcome. Remove every identifying detail. This is the most-read part of your comment.
03
File at regulations.gov
Reference file code CMS-1848-P. Opt in to email confirmation so you receive a tracking number. Keep it to one page where you can.
04
Share it with colleagues
Forward the alert to colleagues and to whoever handles regulatory correspondence at your organization. The number of individually written comments is what carries.
Comments will shape what CMS finalizes.
CMS has expressly solicited comment on the certification standards and the conditions of payment for these codes. The question remains open until September 14.
Comments are posted publicly on regulations.gov, including your name. Do not include patient-identifying information, and do not name your employer unless you are authorized to speak for it. Proposed rule: 91 FR 43842, docket CMS-2026-2377, file code CMS-1848-P, RIN 0938-AV82.