The Centers for Medicare & Medicaid Services (CMS) finalized changes to the 2025 Physician Fee Schedule with expansions to Caregiver Training Services (CTS) - most notably by adding: telemedicine, caregiver assessment, and training for direct care tasks. Details on the 2025 proposed rule can be found in our earlier post here.

CMS confirmed these proposals and made a few additional clarifications, as follows:

• Training can be delivered by auxiliary staff of qualifying billing providers: CMS clarified that auxiliary staff to billing providers can provide training. Qualifying billing practitioners include nurse practitioners (NPs), clinical nurse specialists (CNSs), certified nurse midwives (CNMs), physician assistants (PAs), and clinical psychologists (CPs). Other providers can bill directly for training but not for auxiliary personnel. These include clinical social workers, marriage & family therapists, and mental health counselors.

• Training for ‘direct care’ tasks can include a broad range of tasks: CMS clarified that its examples of direct care tasks were not exhaustive and could include many topics that are reasonable and necessary to train a caregiver on who assists in carrying out a treatment plan.

• Direct care CTS designated as 'sometimes therapy': This facilitates payment to outpatient physical therapy, occupational therapy, and speech therapy providers and their assistants, when they provide training on direct care tasks to family caregivers. Similar to the other CTS codes, this would need to be under a therapy plan of care.

• Registered Dieticians (RDs) and nutrition professionals can be qualifying providers: CMS added RDs and nutrition specialists to providers who can bill for CTS, only under a patient-centered care plan for medical nutrition therapy.

• Duplicative services with CTS: CMS confirmed that CTS would not be billable for training that's already being billed for patients under a home health plan of care, receiving in-home therapy, or receiving DME services for the involved equipment. CTS would be permitted if the patient is receiving these services for a separate issue.

• HCPSC codes assigned: CMS provided the published codes for billing the newly-added direct care tasks and 1:1 behavioral health training. 

Requirements for Caregiver Training haven’t changed since 2024:

• Caregiver training services are considered ‘reasonable and necessary’ when they are integral to a patient’s treatment plan and the patient will need assistance in carrying out the treatment plan

• Training topics need to be aligned to the patient treatment plan and designed to support the desired patient outcomes 

• Training activities need to be identified and documented in the treatment plan

• Caregiver training services can be provided in tandem with direct patient services

• Services can be provided to more than 1 caregiver of a patient, and do not have volume limits. Documentation of why each training occurrence is reasonable and necessary is required to be documented in the EMR

• Services can be provided by multiple kinds of providers depending on the training code. This includes PTs, OTs, clinical psychologists, physician assistants, clinical nurse specialists, and nurse practitioners

• The definition of “Caregiver” is the same as in 2024: “an adult family member or other individual who has a significant relationship with, and who provides a broad range of assistance to, an individual with a chronic or other health condition, disability, or functional limitation” and “a family member, friend, or neighbor who provides unpaid assistance to a person with a chronic illness or disabling condition.”

• Our summary of Caregiver Training Services in the 2024 Physician Fee Schedule is here

Here are the relevant Caregiver Training reimbursement codes, their definitions, and their RVUs:

‍