Caregiver Training Codes: Who May Report Them, and What the Record Has to Show

The first thing that confuses people about this family is that it is not one family. It is four groups added in two waves, and half of them are CPT codes while half are HCPCS Level II codes CMS created itself because no CPT code described the service. A biller looking for all of them in one place will not find them.

CMS's long-standing position was that Medicare coverage runs to services that are reasonable and necessary for the diagnosis or treatment of an individual patient's illness or injury — and that services furnished to somebody who is not the patient therefore fall outside it. When CMS first set out that reasoning in the context of care management, the example it gave of what was excluded was communication with caregivers. On that reading, none of these codes could be paid, and for a while none of them were: CMS declined even to review the recommended values for the behavior management codes.

What changed is the characterization, not the statute. CMS concluded that where a caregiver is being trained to assist the patient in carrying out a treatment plan the practitioner has already established — acting, in effect, as a proxy for a patient who cannot follow the plan alone — the training is reasonable and necessary for that patient. The service is furnished to the caregiver and is for the patient.

Four things travel with every code in the family, and two of them are documentation requirements stated as conditions of payment rather than as good practice.

An established plan, first

A treatment plan — or, where the practitioner is a therapist, a therapy plan of care — has to be in place before the training is furnished, and the training has to be congruent with it and designed to produce the outcomes it sets. Caregiver training is not the service that establishes the plan.

An identified need, documented

The treating practitioner must have identified a need to involve and train one or more caregivers to assist the patient in carrying out that plan, and that identified need must be documented in the patient's medical record.

The patient's consent, for the named caregivers, documented

The patient or their representative must consent to the specific caregiver or caregivers receiving the training, and the consent must be documented in the patient's medical record. CMS considered and rejected the argument that consent to the plan of care covers it: general consent to treatment does not make a patient aware of the two things that are unusual here, which are that the service happens outside their presence and that the cost-sharing on it is theirs.

The patient is not present

The codes are written for training furnished without the patient there, and CMS treats that as deliberate rather than incidental — the point is that the practitioner's and the caregiver's attention is on the training. A session with the patient present is a different service.

This is where the practical answer diverges by discipline, and it is the question the search traffic keeps asking. Two separate rules are in play: whether the service is a therapy service, and who holds the right to bill it.

Physical, occupational and speech-language therapy

CMS designated the caregiver training codes as "sometimes therapy" services. The designation means exactly what it says: when a physical therapist, occupational therapist or speech-language pathologist furnishes them, they are always furnished under a therapy plan of care. So a speech-language pathologist does report caregiver training, and reports it as therapy — the swallowing, feeding and communication ground in the functional-performance group is squarely within that scope.

Physicians and non-physician practitioners

The same code numbers are available to physicians and non-physician practitioners outside a therapy plan of care, where the training is not integral to one, furnished instead under a treatment plan. The consequence for claim build is that the code number alone does not tell you whether the line is a therapy service — who furnished it and under which plan does.

Who may bill, and who may bill only what they performed

Physicians, nurse practitioners, clinical nurse specialists, certified nurse-midwives, physician assistants and clinical psychologists may bill for caregiver training they personally performed or that was performed incident-to their professional services. Clinical social workers, marriage and family therapists and mental health counselors may bill directly for caregiver training they personally perform for the diagnosis or treatment of mental illness — but not for training furnished incident to by auxiliary personnel, because they are not authorized to supervise and bill for incident-to services at all.

Registered dietitians and nutrition professionals

Narrowest of all. They may furnish only the direct-care group, only where the identified need relates to a care plan for medical nutrition therapy, and only within the population they may bill medical nutrition therapy for in the first place. The limitation on the underlying benefit carries straight through to the training.

Direct-care training is not billable where the caregiver training in question is already being separately billed for a patient under a home health plan of care, receiving at-home therapy, or receiving durable medical equipment services for the involved equipment and supplies. The reasoning is specific and checkable: payment to a supplier of an infusion pump already includes the supplies used with it and the obligation to train the beneficiary or caregiver on them, and payment under the surgical dressings benefit already includes training on how to change the dressings. Billing caregiver training on top would pay twice for one thing.

One boundary that is not an overlap: CMS has confirmed that furnishing caregiver training does not affect a patient's eligibility for other Medicare services that are reasonable and necessary. And a boundary that catches people from the other direction — Medicare pays enrolled practitioners under the fee schedule, never caregivers. These codes pay the practitioner for training; they are not a mechanism for compensating a family member.

All ten codes went onto the Medicare Telehealth Services List for CY 2025, and CMS put them there on a provisional basis — the category it used for services it thought were plausibly deliverable remotely but for which it wanted more evidence before committing.

That qualifier no longer exists. In the CY 2026 final rule CMS eliminated the provisional and permanent designations from the list altogether, simplifying its own review criteria and stating that every code then on the list stays on it and that everything listed is now included on a permanent basis. So a source describing these codes as provisionally on the telehealth list is describing a distinction that has been abolished — and, separately, the list is a live document. Whether a given code is on it today is a question for the list itself rather than for any article, and the wider Medicare telehealth billing conditions still apply on top of it.