Through the collective advocacy of the Act on RAISE campaign and the Cancer Caregiving Collaborative, the National Alliance for Caregiving (NAC) mobilized 36 organizations to sign-on to a comment letter submitted on September 9 to the Centers for Medicare and Medicaid (CMS) CY 2025 Physician Fee Schedule (PFS) proposed rule.
“By advocating for Medicare to expand caregiver training services, we’re not just changing policy – we’re revolutionizing how we value family caregivers,” stated Jason Resendez, President and CEO of NAC. “These proposed rules, if adopted, would mark a pivotal shift towards a healthcare system that truly recognizes, empowers, and integrates family caregivers as essential partners in patient care.”
Specifically, NAC outlined support for policy changes that:
- Establish new coding and payment opportunities for caregiver training services (CTS) for specific clinical skills.
- Provisionally add CTS to the Medicare Telehealth Services List.
- Establish a new coding and payment allowance for caregiver behavior management and modification training for caregiver(s) of an individual patient, and
- Allow for verbal consent for CTS.
- Provisionally add CTS to the Medicare Telehealth Services List.
In addition, NAC encouraged CMS to consider addressing the following as it finalizes the proposed rule:
- Allow more types of healthcare workers to provide caregiver training services. This would help increase access to training.
- Set clear standards for caregiver training or point to existing high-quality training programs as examples. This ensures caregivers receive quality training.
- Make it clear that these new caregiver training services are meant to add to, not replace, the home health aides’ services that Medicare already covers.
- Make sure the payment rates for caregiver training services are high enough to encourage healthcare providers to offer them. Also, think about how requiring patients to pay part of the cost (co-pays) might affect how widely these services are used.
The annual updates to the PFS provide an ongoing opportunity to advance vision of the National Strategy to Support Family Caregivers related to strengthening partnerships and engagement with family caregivers in care teams. These updates allow us to identify, implement, and improve policies that ensure family caregivers are fully recognized and integrated as essential members in patient care.
For more information on this proposed rule, read here. Read comment letters from NAC, Cancer Caregiving Collaborative and Act on RAISE.




