Change 1

Updated for the CY 2027 Medicare Physician Fee Schedule Final Rule (CMS-1848-F), released Nov 4, 2026. Effective Jan 1, 2027. Last verified: November 5, 2026

Help center · Who furnishes and who bills

Can a coach work as an independent contractor for a practice?

Answered by Angel Reyes, MCHES®Last verified: November 5, 2026

Short answer

The final rule doesn't address contracting arrangements. Contractor, employment and CBO arrangements all raise supervision, reassignment and compliance questions, so have healthcare counsel review any agreement.

The toolkit includes a services-agreement template marked "attorney review required." It's a starting point for that conversation, not a finished contract.

Didn't find your answer? Browse the help center or contact us. Educational only; not legal, billing, coding or clinical advice. Your supervising practitioner's and organization's policies come first.