Medicare (CMS) is one step away from paying for Nurse Coaching.
CMS/Medicare has proposed covering Health and Wellbeing Coaching – and named AHNCC NC-BC as an approved certification.
What the proposal doesn’t yet recognize is that a licensed nurse doesn’t need supervision to coach, educate and guide a patient toward lasting lifestyle change.
CMS is asking for public comments. We have until September 14 to answer.
Individual, follow-up, and group coaching
Recognition, and a payment mechanism
In the proposed 2027 Physician Fee Schedule, CMS proposes 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 Board-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 September 14.
A condition for payment that does not fit licensed nurses
The proposal treats everyone providing these services as auxiliary personnel working under the direct supervision of a billing practitioner. That framing fits non-licensed coaches; it does not fit a Registered Nurse or Advanced Practice Registered Nurse holding a state regulated license.
Health promotion, patient education, and behavior-change coaching are already independent functions of nursing under every state nurse practice act. No state requires supervision to provide them.
Why the supervision condition warrants revision
It duplicates oversight that already exists
Nurses answer to state boards of professional regulation that oversee continuing education and disciplinary enforcement. Nurse Coaching Board Certification assures competency. Supervision for Nurse Coaches adds an access barrier to care, not a safeguard.
It applies a standard that is not applicable to the licensed professional nurse
Licensure should determine oversight, not employment setting
The proposed rule would require coaches employed by community-based organizations to work under general supervision.
Under the proposed rule, employment setting, not licensure, would set the standard.
It concentrates care where care is already available
Requiring supervision for Nurse Coaching services limits where beneficiaries can receive it.
Licensed nurses do not need supervision to coach patients. That work is already within their scope of practice.
Applying a supervision requirement ties the service to a billing provider’s schedule rather than the patient’s need, and that constraint particularly affects rural and underserved communities where Medicare enrollment is highest.
What to tell CMS
Finalize the payment
Remove the supervision condition for licensed nurses
Name Nurse Coaches, and establish a direct billing pathway
List AHNCC board-certified Nurse Coaches among credentialed billing providers for health and wellbeing coaching services and build a route for direct billing.
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.
Individual comment
Nursing organization comment
Practice or health system comment
Action alert one-pager
How to submit
Write it in your own words
Add one patient story
- Type your comment in the provided box.
- If required, reference file code CMS-1848-P.
- Select “Nurse” from the “What is your comment about” dropdown.
- Opt in to email confirmation so you receive a tracking number.
Share it with colleagues and your organization
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.
Comments are accepted until September 14, 2026.
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.