Comment on CMS-2026-2377-0002

I support the proposal to set conditions of payment and national valuation for health and well-being coaching under CPT codes 0591T, 0592T, and 0593T. I am a registered nurse with a Bachelor of Science in Nursing and the owner of It Is Well Nurse Coach. I hold two board certifications from the American Holistic Nurses Credentialing Corporation: Nurse Coach Board-Certified (NC-BC) and Board-Certified Holistic Nurse (HNB-BC). AHNCC is one of the credentialing bodies this rule names. I worked in value-based care at Iora Health, where health coaches were part of the primary care team for Medicare patients. I saw what the model in this proposal describes. Coaches met with patients between medical visits, worked on the goals patients set for themselves, and followed up often enough to keep change going. Patients with diabetes, high blood pressure, and heart disease managed their conditions better. Some reduced medications. Fewer ended up in urgent care. The coaching was not an add-on. It was often the part of the care team that produced the behavior change the medical visits alone could not. One example from our Hyde Park, Massachusetts clinic. A patient with chronic hypertension was on three blood pressure medications. His health coach met with him weekly on lifestyle changes, but over months his blood pressure never improved. On one visit the coach asked him to bring in all his medication bottles and the RN joined to review them. It turned out the patient could not read. He could not tell the bottles apart and was not taking the medications correctly. Once we found that, we set him up to come in weekly to have a pill planner filled while he continued coaching. His blood pressure came under control and he went from three medications to one. The coach built the relationship and caught the problem. The RN review is what surfaced the cause. Neither piece works as well without the other, and neither happens in a standard office visit. I support naming the AHNCC Certified Nurse Coach standards as a qualifying certification. Nurse coaches certified under AHNCC are trained in behavior change, motivational interviewing, and health promotion, and are held to a national standard. Tying payment to recognized certification — AHNCC, the National Board for Health and Wellness Coaching, and NCHEC — protects patients. Keep these requirements in the final rule. On supervision: I agree with the flexibility in the proposal, and I ask CMS to go with the broadest supervision that works, including general supervision where certification is met. This is low-risk work. I understand Medicare has rules for how it pays and who supervises. My point is that registered nurses are licensed to practice with clinical judgment, and an RN can both deliver this coaching and supervise non-medical-degree health and wellness coaches on a care team. Requiring direct physician supervision for every session would cut access, especially in rural and underserved areas, without adding safety that board certification and RN oversight do not already provide. On telehealth: keep these services on the Medicare Telehealth Services List, including audio-visual and, where appropriate, audio-only. Coaching is built on the relationship, not the setting, and for many patients remote access is the difference between getting support and getting none. On G-codes for CY 2027: price the existing CPT codes now so patients and providers can start using them. If CMS later moves to G-codes, keep the certification standards and national payment established here, and keep the coding stable for the small practices and community organizations that will depend on it. Thank you for advancing payment for prevention, behavior change, and the nurses and coaches who do this work. I ask CMS to finalize it. Kathleen Meleedy BSN, RN, NC-BC, HNB-BC It Is Well Coaching & Consulting,