Billing codes · HCPCS code
G0447 and G0473: can a dietitian bill Medicare obesity counseling?
By Javier Alvarez · Updated · 4 min read
| G0447 | Face-to-face behavioral counseling for obesity, 15 minutes |
|---|---|
| G0473 | Group behavioral counseling for obesity (2-10), 30 minutes |
| Coverage | NCD 210.12: BMI 30 or higher, primary care setting |
| Frequency | Up to 22 sessions in 12 months (G0447 + G0473 combined) |
| Who bills (professional claims) | Primary care specialties only: general practice, family medicine, internal medicine, OB/GYN, pediatrics, geriatrics, NP, CNS, PA |
| Registered dietitian | Can't bill directly; may furnish it incident-to a primary care practitioner |
| Cost sharing | Medicare coinsurance and Part B deductible waived |
| Telehealth (2026 list) | G0447 yes; G0473 added for 2026 |
G0447 looks like it was written for dietitians: behavioral counseling for obesity, diet and exercise, 15-minute sessions. Yet a dietitian who bills it to Medicare under their own NPI gets a denial. The reason isn't the counseling. It's who Medicare allows to bill the code, and where.
What G0447 and G0473 cover
Both codes belong to Medicare's intensive behavioral therapy (IBT) for obesity benefit, NCD 210.12, effective November 29, 2011:
- G0447: face-to-face behavioral counseling for obesity, 15 minutes.
- G0473: face-to-face behavioral counseling for obesity, group (2–10), 30 minutes (effective 2015).
Coverage requires:
- BMI of 30 kg/m² or more, in a beneficiary who is competent and alert during counseling
- Intensive counseling built on the "5 As" (Assess, Advise, Agree, Assist, Arrange), focused on diet and exercise
- A schedule: one visit a week in month 1, every other week in months 2–6, then monthly in months 7–12 if the patient lost at least 3 kg by the 6-month reassessment
- A primary care setting and a primary care practitioner
CMS's claims manual caps the benefit at 22 sessions in a 12-month period, G0447 and G0473 combined, with a BMI code for 30 or higher (Z68.30–Z68.45; see Z68 BMI codes). The Medicare coinsurance and Part B deductible are waived (Claims Processing Manual, ch. 18, §200). The Medicare practitioner MUE is 1 unit per day for each code.
Medicare's primary-care requirement
This is where dietitians get stuck. The NCD covers IBT only when "furnished by a qualified primary care physician or other primary care practitioner and in a primary care setting." The claims manual turns that into two hard edits on professional claims:
Specialties allowed to bill G0447/G0473: 01 general practice, 08 family practice, 11 internal medicine, 16 OB/GYN, 37 pediatric medicine, 38 geriatric medicine, 50 nurse practitioner, 89 clinical nurse specialist, 97 physician assistant. Claims from any other specialty are denied.
Places of service allowed: 11 office, 19 and 22 outpatient hospital, 49 independent clinic, 71 public health clinic.
A registered dietitian enrolls in Medicare as specialty 71 (dietitian/nutritionist), which isn't on the list. So a G0447 claim under a dietitian's own NPI is denied, however good the counseling was.
RDs and incident-to (and its risks)
CMS's decision memo for the benefit says that in the primary care office setting, Medicare may cover IBT billed by the primary care physician or practitioner and furnished by auxiliary personnel under the incident-to conditions in 42 CFR 410.26(b). A registered dietitian working in a primary care practice can be that auxiliary personnel.
What that means in practice:
- The claim goes out under the primary care practitioner, not you. The payment goes to the practice.
- Incident-to conditions must be met: you're employed by or contracted with the practice, the billing practitioner started the course of treatment, and the supervision requirement CMS sets for incident-to services is met. Supervision rules have shifted in recent years, so check CMS's current PFS rules and your MAC.
- The setting must be primary care. A private nutrition practice isn't a primary care setting, even if a physician sends the patient to you.
The risks are real. Incident-to billing that doesn't meet the conditions is an overpayment, and it's the billing practitioner's liability. And the incident-to route doesn't carry over to MNT: CMS says 97802–97804 "cannot be paid incident to physician services" (ch. 4, §300.4). For the broader rules, see can dietitians bill incident-to?
What a dietitian bills instead
It depends on the patient's coverage:
| Patient | Route |
|---|---|
| Medicare, obesity and type 2 diabetes | Medicare MNT: 97802/97803 with the diabetes diagnosis and a physician referral |
| Medicare, obesity only | No MNT benefit. Options: IBT incident-to in a primary care practice (G0447 billed by the practitioner), or private pay under Medicare's rules for non-covered services |
| Commercial, obesity | Usually 97802/97803 with an E66 obesity code and a BMI code, under the plan's preventive or medical benefit |
| Commercial plan that lists G0447 | Only if your contract and credentialing allow a dietitian to bill it; ask first |
Several commercial policies list G0447 among covered codes, including Aetna's CPB 0049 and the preventive policies from Cigna (A004) and UnitedHealthcare (MP.016.59). A code on a coverage list tells you what the member's benefit covers. It doesn't say who may bill it. That's in your contract.
Patients on GLP-1 medications often fall into the obesity-only group; GLP-1 nutrition billing covers how those visits are coded commercially.
Telehealth
G0447 is on the Medicare telehealth list, and G0473 was added for 2026 (MLN901705). That doesn't change who may bill: the specialty and setting rules still apply to the billing practitioner.
Common G0447 denials
- Billed by specialty 71 (dietitian): denied under the specialty edit. Deliver the service incident-to a primary care practitioner, or use MNT codes where the patient qualifies.
- POS not on the allowed list: denied. IBT belongs in the primary care setting.
- No BMI code of 30 or higher: denied under the diagnosis edit.
- More than 22 sessions in 12 months, or monthly visits continued without a 3 kg loss: denied as over frequency.