Comment on CMS-2026-1916-0001

On behalf of the International Nurse Coaching Association, a nonprofit membership organization that champions root cause healing, integrative care, and evidence-based coaching to improve health. We write in strong support of the Centers for Medicare & Medicaid Services’ (CMS) proposal to establish national payment for CPT codes 0591T (health and well-being coaching; individual, initial assessment), 0592T (individual follow-up session), and 0593T (group session). Establishing consistent national payment for these services is a decisive and long-overdue step toward integrating evidence-based health and well-being coaching into the care of Medicaid and Medicare beneficiaries, particularly those living with or at risk for chronic conditions. As CMS finalizes this policy, we respectfully urge the agency to explicitly recognize Registered and Advanced Practice Nurses who hold national board certification from the American Holistic Nurses Credentialing Corporation (AHNCC) as a Nurse Coach, Board Certified (NC-BC), and/or Health and Wellness Nurse Coach, Board Certified (HWNC-BC) credentials, as qualified providers of services billed under these codes. Nurses bring unmatched licensure, education, and clinical accountability to coaching services. Registered and Advanced Practice Nurses complete rigorous, accredited academic preparation in the biological, behavioral, and social sciences; pass a national licensure examination (NCLEX-RN) and/or advanced board certification, and practice under state licensure with defined scopes of practice, continuing education requirements, and professional accountability to state boards of nursing. Nursing has been rated the most trusted profession in the United States for more than two decades. When beneficiaries receive health and well-being coaching from a Nurse Coach, they receive it from a licensed clinician who can recognize warning signs, understand comorbidities, medications, and chronic disease, coordinate with the broader care team, and escalate concerns and safeguard vulnerable populations. In addition, Nurses practice relationship-based care with clients during the most vulnerable times of their lives while providing integrative interventions to create healing environments and lasting lifestyle change. AHNCC national board certification ensures standardized, verifiable competency in Nurse Coaching. Nurse Coaching is a recognized nursing specialization with published scope and competencies of practice by the American Nurses Association. AHNCC board certification requires an active, unrestricted RN or APN license; documented nursing practice experience; completion of dedicated nurse coach education grounded in established coaching competencies, motivational interviewing, and behavior-change science; supervised coaching practice hours; and successful completion of a national certification examination, with ongoing recertification requirements. This credentialing pathway parallels the third-party certification standards CMS has recognized for other coaching credentials, and it exceeds them by anchoring certification to an underlying clinical license. Board-certified nurse coaches advance the goals of this proposed rule. Health and well-being coaching delivered by Nurse Coaches supports sustainable behavior change, such as in nutrition, physical activity, stress management, sleep, tobacco cessation, and chronic disease self-management, that are precisely the drivers of avoidable utilization and cost in specific populations. Because Nurses practice in every community and care setting, including rural and underserved areas where Medicaid/Medicare enrollment is highest, recognizing AHNCC board-certified nurse coaches will meaningfully expand beneficiary access. The group coaching code (0593T) in particular offers a scalable, cost-effective modality that Nurse Coaches are well prepared to lead. Recommendations. We respectfully request that CMS: 1.Finalize national payment for CPT codes 0591T, 0592T, and 0593T as proposed; 2.Explicitly include Nurses holding AHNCC national board certification (NC-BC, HWNC-BC) among the qualified practitioners eligible to furnish and bill these services; 3.Establish payment rates that reflect the time, intensity, and clinical expertise these services require, ensuring parity with comparable behavior-change and chronic care management services; and 4.Preserve coverage of both individual and group coaching modalities to maximize access and equity. Thank you for your leadership in advancing prevention, chronic disease management, and whole-person care. The International Nurse Coaching Association welcomes the opportunity to serve as a resource to CMS on Nurse Coach education, certification, and practice.