On July 13, Medicare published its proposed CY2024 Physician Fee Schedule, and will accept comments on it through September 11. Caregiver Training Services was a new addition to reimbursed services.

We’re excited and supportive of this new reimbursement and see this as just one step in a broader reimbursement trend for caregiver training & support. We read the full fee schedule and summarized our takeaways below.

First, here are CMS’s own words on the new coverage: “For CY 2024, we propose to establish an active payment status for CPT codes 96202 and 96203 (caregiver behavior management/modification training services) and CPT codes 9X015, 9X016, and 9X017 (caregiver training services under a therapy plan of care established by a PT, OT, SLP). These codes allow treating practitioners to report the training furnished to a caregiver, in tandem with the diagnostic and treatment services furnished directly to the patient, in strategies and specific activities to assist the patient to carry out the treatment plan.”

After reading the full proposed rule, we see that the coverage:

• Extends to many areas of care: Listed examples include dementia, post-operative care, stroke recovery, and general cognitive disabilities. The services are considered appropriate if a clinician believes involvement of a caregiver is necessary for a successful outcome of the patient, when the patient agrees to caregiver involvement (as appropriate), and when the training is tied to a specific care plan. 
• Applies to a ‘lay person’ who is helping the patient with a specific plan of care. The fee schedule lists family, friends, neighbors, and guardians as examples of this type of person. CMS is looking for comments on their definition of a caregiver.
• Can be provided to multiple caregivers of a patient. The CPT codes were designed to support training of multiple caregivers. The proposed draft limits payments to once per beneficiary under each practitioner. CMS is asking for comments on whether to allow multiple sessions based on different scenarios, e.g., for the same patient by the same practitioner later in the year.
• Can be delivered by a variety of practitioners. Training can be delivered by physicians, non-physician practitioners (e.g., NP, PA, clinical nurse specialist, clinical psychologist), and therapies (PT, OT, SLP).
• Requires patient (or representative) consent and identified need in the medical record: Practitioners will need to get patient consent to train caregivers, and document the need for caregiver training to carry out the patient care plan.

Here’s a summary of the new codes:

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