The Centers for Medicare & Medicaid Services (CMS) proposed 2025 Physician Fee Schedule demonstrates continued investment in Caregiver Training Services. We are excited to see more support for caregiver’s needs through the expansion of these training services and the ability to deliver the services remotely. 

Here are some highlights from the proposed Physician Fee Schedule:

• All Caregiver Training Services codes added to the telemedicine list: 2024 was the first year that CMS provided payment codes for caregiver training. Last year, they limited training to in-person services. In 2025 they are provisionally adding all Caregiver Training codes to the telemedicine list. They will monitor the efficacy of these services, then determine whether to permanently add them to the telemedicine list. It’s a win for caregivers who often need training in-the-moment at home. 

• New Caregiver Training Services codes added for ‘direct care’ tasks, such as wound care, infection control, and medication administration: These new codes recognize that caregivers often need to provide hands-on treatments to patients, which may includes nursing tasks like medication administration. The codes can also support training to reduce complications and monitor the patient.

• New Caregiver Training Services codes added to support 1:1 training in behavioral management & modification: These expand on 2024 codes that required group-based training. The new codes recognize the need for 1:1 caregiver training to support mental health needs such as depression, substance use, or difficult behaviors.

• Assessing a caregiver’s training needs can be reimbursed using existing code: CMS would allow existing code 96161 to be used to assess a caregiver’s current skills, knowledge, health risks, or other considerations to inform caregiver training services. Patient consent would be needed prior to caregiver assessment. 

• Patient consent can be verbal: In 2024 CMS requested written patient consent to be documented in the medical record. In 2025 they are changing this to allow verbal patient consent, which simplifies documentation. 

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 specific 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: