Welcome to guest blogger, OT and Director of the Just for OT Practitioner to Coach Program, Jaclyn Schwartz, PhD, OTR/L
CMS is considering national Medicare payment for health and well-being coaching. But under the current proposal, being an occupational therapy practitioner may not be enough to qualify. That makes this more than a coding update. It is a live question about how occupational therapy is understood, what coaching requires, and who should be prepared to provide it.
Coaching skills already have a practical place in occupational therapy. An OT practitioner might use them while helping a parent try new strategies with a child, supporting a caregiver to make changes that fit family routines, or helping a client carry recommendations into daily life at home. Coaching can help us move from telling someone what to do toward helping them decide what is workable, meaningful, and sustainable.
So, can occupational therapy practitioners use the proposed codes? Not yet. The rule is still proposed, and even if finalized, it would not automatically allow every OT practitioner or health coach to bill Medicare independently. The details of qualifications, supervision, billing, and implementation still matter.
This article explains three things:
• What CMS is proposing for health and well-being coaching
• Why OT belongs in the conversation
• Why professional recognition and coaching competence both matter
What CMS Is Proposing for Health and Well-Being Coaching
In the Calendar Year 2027 Medicare Physicians Fee Schedule proposed rule, CMS proposes conditions of payment and national valuation for three existing Category III CPT codes:
• 0591T: Individual initial assessment, 60 to 90 minutes
• 0592T: Individual follow-up session, at least 30 minutes
• 0593T: Group coaching for two or more individuals, at least 30 minutes
CMS describes health and well-being coaching as a patient-centered process in which patients
• Determine their goals
• Use self-discovery or active learning
• Receive relevant content education
• Monitor their behaviors to increase accountability
The purpose is to help people develop intrinsic motivation and make sustainable changes that improve health and well-being.
The proposal would allow the services to be performed under direct supervision of a billing practitioner. Health coaches do not have a separate Medicare benefit category, so the proposal would not allow them to enroll and bill Medicare independently. CMS is also asking for feedback on payment, conditions of service, and whether separate HCPCS G-codes would be preferable to pricing the existing CPT codes.
Why Occupational Therapy Belongs in This Conversation
The proposed services focus on behavior change, goal setting, self-management, and long-term health improvement. These areas are familiar to occupational therapy practitioners. We regularly consider how habits, routines, environments, roles, and relationships shape what a person is able to do outside the clinic.
Consider a client who understands a home program but is not using it consistently. The OT practitioner may need to evaluate whether pain, fatigue, cognition, equipment, competing responsibilities, or the physical environment is interfering. Those are skilled OT considerations. A coaching approach can add something different: helping the client identify which change matters most, explore ambivalence, draw on previous successes, and choose an action they feel ready to complete.
The same distinction appears in work with families. An OT practitioner may teach a parent a strategy and demonstrate how to use it. Coaching skills can then help the parent consider how that strategy fits into the family's routines, anticipate barriers, adapt the plan, and decide what they are willing to try before the next visit. The practitioner still brings OT knowledge and clinical reasoning, but the conversation creates more room for the family's expertise and ownership.
This is why coaching can strengthen occupational therapy without replacing it or requiring a new professional identity. Coaching is a skillset and stance that can be used when the central task is helping someone translate knowledge and intention into action.
Recognition and Competence Are Not Competing Positions
AOTA is asking CMS to recognize occupational therapy practitioners as qualified providers of health and well-being coaching services based on the profession’s education and experience in behavior change, habit formation, chronic disease management, health promotion, and meaningful goal attainment. This advocacy is important. Occupational therapy should not be overlooked when CMS defines who may provide services that closely relate to participation in daily health behaviors.
The proposal also raises a reasonable question about what preparation should be required for this specific service. For example, CMS identifies Certified Nurse Coaches as one pathway that could satisfy its proposed qualification requirements. Nurses already receive substantial pre-professional education in health promotion, chronic condition management, communication, and patient education. The additional coaching preparation reflects the requirements of a defined service, not a lack of respect for their professional foundation.
The same distinction may be useful for occupational therapy. OT education provides a strong foundation for addressing habits, routines, behavior change, self-management, and meaningful goals. The remaining question is whether CMS should recognize that preparation on its own, require additional coaching-specific training, or establish a pathway that considers both.
Professional recognition and coaching competence do not have to be competing positions. CMS can acknowledge the relevance of OT education and scope while establishing clear expectations for anyone furnishing a defined health and well-being coaching service. Public comment can help CMS determine how those expectations should apply to occupational therapy practitioners.
What OT Practitioners Can Do Now
The CMS public comment period closes September 14, 2026. Comments can help CMS understand what occupational therapy contributes and how qualification requirements could recognize OT education while maintaining meaningful competency standards.
A useful comment might address:
• How OT education and practice prepare practitioners to address habits, routines, behavior change, chronic condition self-management, and health promotion
• How Medicare beneficiaries could benefit from access to OT practitioners with appropriate coaching preparation
• How CMS could recognize relevant licensure and what else might be necessary to establish coaching competence
Specific practice examples are more useful than broad statements of support. Comments submitted to the federal government become part of the public record, so do not include protected health information or confidential details.
It is also important not to overread the proposal. The policy is not final. It does not guarantee reimbursement, allow health coaches to bill Medicare independently, or establish that OT practitioners may automatically report these codes. Final regulations, payer policies, supervision requirements, and setting-specific procedures would still need to be reviewed.
Health Coaching Policy Is Changing. Preparation Still Matters.
The CMS proposal is a meaningful sign that health and well-being coaching is becoming more visible in health care. For OT, the opportunity is larger than a possible billing code. It is an opportunity to explain how our profession supports real behavior change and to be clear about the preparation needed to do coaching well.
Coaching skills can improve everyday OT practice now, whether we are supporting caregivers, helping clients implement strategies at home, or addressing health behaviors within chronic condition management. Formal recognition may evolve, but occupational therapy practitioners do not need to wait for a billing code to examine how coaching skills could strengthen their current practice.
For readers interested in developing these skills, Aspire OT’s Practitioner-to-Coach program is a National Board for Health and Wellness Coaching (NBHWC) Approved Training Program designed specifically for occupational therapy practitioners. The program provides education in coaching fundamentals, behavior-change skills, ethics, scope, and the use of coaching within or alongside occupational therapy practice.
