Faculty Group Practice Newsletter

G0136 – New Definition for 2026

Effective January 1, 2026, G0136 has a new definition.  CMS proposed to delete this code for 2026.  Due to public comments, CMS chose to keep the code but has changed its definition. The new descriptor shifts the focus from SDoH risk assessment to the administration of a standardized, evidence-based assessment of physical activity and nutrition, refocusing and narrowing their goal to address essential patient behaviors and lifestyle factors with the aim of reducing chronic disease and improve health.  The new definition will identify and use physical activity and nutrition data to adjust treatment plans.

New Descriptor
G0136 - Administration of a standardized, evidence-based assessment of physical activity and nutrition, 5-15 minutes, not more often than every 6 months.

CMS created G0136 and continues to state that this code is not to be used as a screening tool. It is an assessment used when there is a known or suspected need related to the patient’s physical activity level and/or nutrition.  The code is payable when both or either the physical activity or nutrition assessment are performed.

CMS example: “If a beneficiary has recently started a new diet but their physical activity levels have not been assessed, only a physical activity risk assessment may be reasonable and necessary.”  G0136 requires appropriate follow-up with the patient.

G0136 may be billed on the same date as the following services: office visits, hospital discharge (IF the practitioner doing the discharge will be doing the follow-up), Transitional Care Management, Behavioral Health visits or the CMS Annual Wellness Visit.  The patient will have financial responsibility (co-insurance and deductible) when performed with any other service EXCEPT the Medicare Annual Wellness Visit.

G0136 may also be billed on the same date as 90791 psychiatric diagnostic evaluation, and Health Behavior Assessment and Intervention codes 96156, 96158, 96159, 96164, 96165, 96167, and 96168, when performed by a clinical psychologist, not a social worker.

CMS does not believe this assessment will be performed in advance because it is not a screening, it is performed as an assessment based on the practitioner’s evaluation of the patient’s situation. CMS expects that a practitioner who furnishes the risk assessment would, at a  minimum, refer the patient to relevant resources and include the results of the assessment in their MDM, or diagnosis and treatment plan for the visit.

Required Documentation:
1. Identification of a standardized evidence-based assessment tool.
Examples of evidence-based tools include but are not limited to:
Nutrition Assessment Tool examples: Mini-EAT tool, the Starting the Conversation: Diet tool, and Short Dietary Assessment Instruments
Physical Activity Assessment Tool examples: Physical Activity Vital Sign tool, the CHAMPS Physical Activity Questionnaire for Older Adults, and the Rapid Assessment of Physical Activity (RAPA) or Telephone Assessment of Physical Activity (TAPA)

2. Document the results of the assessment in the MDM or diagnosis and treatment plan.
3. G0136 is time based, time spent reviewing the assessment results should be documented separately from any other time and may not be included in your time statement for the visit level.

The frequency limit for billing G0136 remains to be once every 6 months. This code requires appropriate follow-up visits with the patient. You may not bill the G0136 unless you are the provider following up with the patient for their activity level and/or nutrition.

As per the notice sent by Dr. Jorge Rodriguez-Fernandez on 12/30/2025, updated guidance will be shared once the future workflow is defined.

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