In the CY 2026 Physician Fee Schedule (PFS) Final Rule, the Centers for Medicare & Medicaid Services (CMS) made significant changes to the applicable use and providers in the Community Health Integration (CHI) space. If you all recall this was a big win in 2024 for the ability to receive reimbursement for community health workers. I would say the refinements and clarifications in the CY 26 PFS ruling have made it easier for CHI services to be performed and for coding G0019.
Originally finalized in 2024, G0019 describes 60 minutes per month of CHI services performed by certified or trained auxiliary personnel, including community health workers, functioning under the direction of a physician or other qualified practitioner. In 2025, CMS clarified that clinical social workers (CSWs) fall within this category.
Additionally, this key quote was clarified which I would suggest also includes the ability for registered nurses to provide CHI services.
“As we stated previously in the CY 2024 PFS final rule (88 FR 78926), the codes do not limit the types of other health care professionals, such as registered nurses and social workers, that can perform CHI services (and PIN services, as we discuss in the next section) incident to the billing practitioner’s professional services, so long as they meet the requirements to provide all elements of the service included in the code, consistent with the definition of auxiliary personnel at § 410.26(a)(1).”
In the 2026 PFS final rule, CMS further expands that Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) are now included as “certified or trained auxiliary personnel.” This shift acknowledges the CSWs, MFTs, and MHCs already possess training aligned with SDoH assessments, behavioral interventions, and care coordination. Integral to their programs they frequently support patients in navigating community-based and psychosocial resources.
Another major update concerns initiating visits, which establish the clinical need for CHI services. Historically, only E&M visits (excluding low-level staff-performed E&M) and certain preventive services (TCM, AWV) qualified. Stakeholders argued that this limited behavioral health practitioners’ ability to initiate CHI services, even when addressing significant psychosocial barriers to care. In the 2026 ruling additional behavioral health visits were included to service as the initiating visit for establishing CHI services.
This action includes Psychiatric diagnostic evaluation (90791) and Health Behavior Assessment and Intervention Codes (HBAI)
The updated G0019 CHI service definition continues to have changed from addressing an unmet SDoH need to addressing any unmet upstream driver. This includes any factors that affect patient behaviors (such as smoking, poor nutrition, low physical activity, substance misuse, etc.) or potential dietary, behavioral, medical, and environmental drivers to lessen the impacts of the problem(s) addressed in the initiating visit.
CMS did not change the requirements what is included in CHI services. Meaning, CHI services will still be expected to have a person-centered assessment, and care planning that supports coordination of home and community-based services, health system navigation, behavioral change support and self-advocacy building. This also includes the facilitation of access to community resources and social and emotional support.
These refinements reflect the recognition by CMS that behavioral health professionals routinely address upstream factors that impede diagnosis, treatment, and recovery. By expanding workforce eligibility and clarifying training expectations, CMS demonstrates their interest to improve patient access, reduce care bottlenecks, and better integrate medical and behavioral health care.
This expansion is key, as we continue to see access to care issues in ambulatory settings, particularly in rural communities and areas with limited access to behavioral health services.
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