The Centers for Medicare & Medicaid Services (CMS) has released its proposed rule for the CY 2027 Medicare Physician Fee Schedule (CMS-1848-P), and the National Alliance for Caregiving (NAC), together with the Caregiver Nation Coalition (CNC) and the Cancer Caregiving Collaborative (CCC), has submitted formal comments urging CMS to strengthen several provisions that directly affect family caregivers.
The proposed rule addresses caregiver training services, advance care planning, and care management for the seriously ill, and includes a new Request for Information on community-based palliative care. Together, these provisions shape the support available to family caregivers as they help a loved one through chronic illness, disability, or aging.
Key Provisions:
- A clarified dementia caregiver-education quality measure (Q288), confirming that required caregiver education and support extend to family caregivers who are not part of the licensed care team.
- The addition of caregiver training codes to ACO attribution, recognizing caregiver training as a meaningful marker of patient care beginning in performance year 2027.
- Two new Advance Care Planning billing codes (GACP1/GACP2), which for the first time explicitly value clinical staff time — including conversations with family members and surrogates — separately from the billing practitioner’s own time.
- A new MIPS improvement activity on Advance Care Planning conversations, which explicitly names caregivers as intended participants.
- National payment for health and well-being coaching services, including a certification pathway for community-based organization staff operating under general supervision.
Opportunities for Improvement:
- Preserve and strengthen, rather than revalue, Caregiver Training Services (CTS). CMS is weighing whether CTS codes overlap with existing E/M services. NAC and CNC argue the two are not duplicative — CTS is furnished to the caregiver, often without the patient present, and low utilization to date reflects limited provider awareness of a two-year-old code set, not a lack of need. The letter also asks CMS to resolve several outstanding technical questions, including cost-sharing treatment, billing-threshold alignment with Community Health Integration and Principal Illness Navigation, and a timed-service billing contradiction unresolved since the CY 2025 final rule.
- Build community-based palliative care eligibility around comprehensive need, not a terminal prognosis. In response to CMS’s RFI, the letter offers six recommendations, including situating caregiver strain within a broader, needs-based assessment rather than as a standalone eligibility trigger, and designing eligibility and documentation standards to accommodate fluctuating caregiving intensity .
- Make caregiver assessment and caregiver education required, not optional, elements of any future care management benefit for the seriously ill and extend “continuity with a designated team member” to include continuity with the family caregiver, building hospital-to-home transition requirements on the CARE Act.
- Preserve visibility of caregiver engagement in MIPS. CMS proposes folding a standalone caregiver-engagement improvement activity (IA_BE_15) into a broader care-planning activity. NAC and CNC ask CMS to retain explicit reference to “family or caregivers” in the surviving activity’s description so clinicians don’t lose a clear pathway to credit for caregiver-engagement work.
- Expand who can furnish CTS. The letter asks CMS to extend the same general-supervision, community-based-organization flexibility proposed for health and well-being coaching to caregiver training — and to allow registered nurses, who are currently excluded, to conduct it.
Caregiver advocates will continue to advocate for clearer CTS billing standards, needs-based palliative care eligibility, required caregiver elements in care management, and full inclusion of family caregivers as CMS finalizes this rule and considers future Innovation Center models.
Read the full comment letter for complete recommendations and supporting citations.
