Social needs screening outreach: the 2026 Medicare code change, Medicaid guidance, privacy and patient messages

Primary care practices, community health centers, free clinics and care management teams ask patients about food, housing, transportation, utilities and safety because those needs get in the way of care. Telling patients that you ask, and what happens when they answer, is part of outreach. It is also an area where the rules moved under people’s feet. The Medicare code that paid for a social determinants of health risk assessment was rewritten for 2026, and the federal Medicaid guidance on covering health-related social needs was rescinded in 2025. Pages and scripts written in 2024 can now be wrong. This guide covers what changed, what a practice can still say, how to share information with community groups under HIPAA and 42 CFR Part 2, and how to word invitations without promising help you cannot deliver.

Related topics have their own guides and are not repeated here. Safety net clinics are covered in our guides to community health center marketing and free clinic marketing, the Medicare wellness visit in our guide to annual wellness visit outreach, and follow-up after a hospital stay in our guide to transitional care management outreach.

What happened to the Medicare social needs code

In the CY 2024 Physician Fee Schedule final rule, CMS created HCPCS code G0136 for administration of a standardized, evidence-based social determinants of health risk assessment tool, 5 to 15 minutes, limited to once in 6 months. In the CY 2026 proposed rule, CMS said that after reviewing utilization it had come to believe the resource costs of G0136 were already accounted for in existing codes, including office visits, and proposed deleting the code for 2026.

The final rule, published November 5, 2025, did not delete the code. After comments, CMS said it was retaining G0136 and revising its descriptor to read: administration of a standardized, evidence-based assessment of physical activity and nutrition, 5 to 15 minutes, with the same 6 month limit. CMS also revised the annual wellness visit definitions in 42 CFR 410.15 so that the optional element is now a physical activity and nutrition risk assessment furnished at the discretion of the health professional and the beneficiary. The rule says the code remains an optional, additional element of the annual wellness visit with an additional payment and no beneficiary cost sharing, and that other billing rules stay the same.

In plain terms: starting in 2026, G0136 no longer describes a social needs screening. The CY 2027 proposed rule, published July 16, 2026, lists G0136 as the code for physical activity and nutritional assessment services. We could not find a proposal to restore the social needs version on October 30, 2026. Check the final CY 2027 rule when CMS publishes it.

• Remove any page, flyer or script that tells Medicare patients a social needs screening is a separately paid, no cost add-on to their wellness visit in 2026.
• Do not tell patients what a visit will cost based on a 2024 or 2025 billing article. Have the billing team confirm the current year’s rules.
• If you now offer the physical activity and nutrition assessment, describe it by that name, and keep it separate from the social needs questions in your materials.
• Date any billing statement on the page and name the rule it comes from.

The Medicaid guidance that was rescinded

In November 2023, the CMS Center for Medicaid and CHIP Services issued an informational bulletin and a framework on covering services and supports that address health-related social needs in Medicaid and CHIP, and a December 2024 bulletin updated and replaced both. On March 4, 2025, CMCS rescinded the November 2023 and December 2024 bulletins. The rescission says CMS will consider state applications to cover these services on a case-by-case basis under the Social Security Act and federal regulations, without reference to those bulletins or the framework.

That leaves coverage of things like meals or housing supports to each state’s approved Medicaid program, which a practice cannot describe from federal guidance alone. A September 2025 archived copy of the Medicaid.gov page on health-related social needs still described state options such as state plan authorities, home and community-based services waivers, managed care in lieu of services and settings, and section 1115 demonstrations, but it does not tell you what your state covers.

• Do not tell Medicaid patients that a food, housing or transportation benefit is available unless your state program or the patient’s health plan confirms it in writing.
• Link to the state Medicaid agency or the patient’s plan for benefit questions instead of paraphrasing coverage on your own page.
• Remove page copy that quotes the 2023 framework or the 2024 bulletin as current policy.

What a practice can honestly say

Asking about social needs does not depend on a billing code. A practice can still ask, listen and refer. What changes is how you describe it. The safest description is what your staff actually does: ask a short set of questions, review the answers with the patient, and share contact details for local organizations that may be able to help.

• Use: “We ask every patient a few questions about food, housing, transportation and safety, because these things affect your health.” Only say “every patient” if that is true at your practice.
• Use: “If you tell us you need help, we can share contact information for local organizations.” Avoid: “We will get you free groceries” or any line that promises help will come.
• Use: “Answering is your choice, and your answers do not change your care.” Avoid wording that makes the questions sound required.
• Say who sees the answers: your care team, and anyone else only as the next section describes.
• Name partner organizations only with their permission, and do not describe their eligibility rules or wait times unless they gave you that text.
• Avoid outcome promises. Do not say screening will lower costs, prevent hospital stays or improve health results at your practice.

Sharing information with community groups

HIPAA defines treatment in 45 CFR 164.501 as the provision, coordination or management of health care and related services by one or more health care providers, including the coordination or management of health care by a health care provider with a third party, consultation between providers, and referral from one provider to another. Whether a particular referral to a food bank, housing agency or legal aid group fits that definition is a question for your privacy officer, not your marketing team. When it is unclear, get the patient’s written authorization under 45 CFR 164.508 before you send their information, or give the patient the organization’s contact details and let them reach out.

42 CFR Part 2 adds a separate layer for substance use disorder records. Under 42 CFR 2.11, a program includes a person or an identified unit that holds itself out as providing, and provides, substance use disorder diagnosis, treatment or referral for treatment, and medical staff in a general medical facility whose primary function is that work. A Part 2 program is one that is also federally assisted. Records from a Part 2 program can be disclosed with written consent that meets 42 CFR 2.31 or under one of the exceptions in the rule. The 2024 final rule that aligned Part 2 more closely with HIPAA took effect April 16, 2024, with a compliance date of February 16, 2026.

• Map every place screening answers go: the chart, a referral platform, a partner’s email inbox, a spreadsheet.
• Send only what the partner needs to help. A food pantry referral does not need diagnoses.
• Keep substance use answers out of referrals to community groups unless your privacy officer has confirmed Part 2 does not apply or the consent meets 42 CFR 2.31.
• Do not put screening answers in email subject lines, text messages or shared calendars.
• If a vendor runs the referral platform, confirm in writing what the agreement with that vendor covers before any patient information goes through it.

Forms, pages and ad tags

A social needs questionnaire collects information that patients may not have told anyone else: that they skip meals, cannot pay a utility bill or feel unsafe at home. Treat it with at least the care you give any intake form.

• Collect screening answers inside the patient portal, on paper or in person, not on a public web page.
• Do not run third party ad or analytics tags on any page where a patient enters screening answers or books a related visit.
• Do not build ad audiences or retargeting lists from people who visited a social needs page.
• Keep the questions out of URLs and page titles, such as a page named “housing-insecurity-form.”
• A public page can explain that you ask these questions and why. It should not collect the answers.

Messages that invite without exposing

A text that says “Do you need food assistance?” can be read on a lock screen by anyone nearby, including the person a patient is afraid of. Keep the subject out of the preview and move the questions to a visit or the portal. These samples use placeholders; replace them with your own details.

• Before a visit: “[Practice name]: Before your visit on [date], please complete a short questionnaire in the portal. Call [phone] with questions. Reply STOP to opt out.”
• After a visit: “[Practice name]: Thank you for your visit with [clinician name]. The information you asked for is in your portal. Call [phone] if you need it another way. Reply STOP to opt out.”
• Reminder: “[Practice name]: Reminder of your visit on [date] at [time]. Call [phone] to change it. Reply STOP to opt out.”

Under 47 CFR 64.1200(a)(9)(iv), calls and texts to wireless numbers made by or on behalf of healthcare providers are exempt from prior express consent only when all of its conditions are met. They go only to the wireless number the patient provided, state the provider’s name and contact details, and are strictly limited to listed purposes, which include appointment and exam confirmations and reminders and wellness checkups. They contain no telemarketing, solicitation or advertising and no billing or other financial content, comply with HIPAA privacy rules, stay concise (generally 160 characters or fewer for a text), are limited to one message a day and three a week, and offer an easy opt out. A message about community resources may not fit a listed purpose, so get the patient’s consent first or use the portal, and ask your attorney.

Working with community partners

Partner pages can help patients find local help, and a partner may list your practice in return. Keep that relationship about patients, not search rankings.

• Link to a partner because the page helps your patients, and use plain anchor text such as the organization’s name.
• Do not trade links in bulk, pay for links or ask partners to add keyword anchors. That is a link scheme, and it adds nothing for patients.
• Do not quote a partner’s statistics, success stories or client counts on your page unless the partner published them and you link the source.
• If a partner tells patients about your practice, give them accurate text about your services and ask them not to promise appointments or prices.
• Under 16 CFR 255.2(b), a consumer endorsement is likely read as what people will generally achieve, and claims must be truthful and substantiated under 15 U.S.C. 45. A story about one patient who got housing help implies others will too.

Illustration: two social needs pages

This is an invented example to show the difference, not a real practice. Page A says “Free help with rent, food and bills! Ask about our no-cost Medicare screening,” collects answers in a web form with an ad pixel, and quotes a 2024 billing article. Page B says “We ask patients about food, housing, transportation and safety because they affect health,” explains that answering is optional, says who sees the answers, says that staff can share contact details for local organizations, collects the questions in the portal, and sends billing questions to the front desk. Page A promises help and a price it cannot back up and leaks sensitive answers. Page B matches what the practice does and the 2026 rules.

Checklist before a social needs campaign goes live

• No page or script describes G0136 as a social needs screening for 2026 dates of service.
• No page cites the rescinded 2023 or 2024 Medicaid guidance as current policy.
• Benefit wording sends patients to their state Medicaid program or plan and promises nothing.
• No promise of help or free services, no outcome claims, no partner statistics without a source.
• Screening answers are collected in the portal, on paper or in person, with no ad or analytics tags.
• Your privacy officer has reviewed what goes to each community partner and when authorization is needed.
• Substance use answers are handled under 42 CFR Part 2 where it applies.
• Texts meet the healthcare message conditions in 47 CFR 64.1200(a)(9)(iv) and keep the subject off the preview.
• Partner links are editorial, few and named plainly.
• A clinician, your billing advisor and a health care attorney approved the page and the messages.

How we help

We build websites, local search, Google Ads, patient lead generation and AI front desk tools for independent practices and health businesses, including primary care practices, community health centers and free clinics. For social needs outreach, that means a site that explains what you ask and why in plain words, billing statements dated and tied to the current rule, intake kept in the portal with no ad tags, and reminders that stay within the federal text rules and keep sensitive subjects off the lock screen. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it.

Sources

• Federal Register: CY 2026 Payment Policies Under the Physician Fee Schedule, final rule (November 5, 2025; HCPCS code G0136 and 42 CFR 410.15)
• Federal Register: CY 2027 Payment Policies Under the Physician Fee Schedule, proposed rule (July 16, 2026)
• CMCS Informational Bulletin: Rescission of Guidance on Health-Related Social Needs (March 4, 2025)
• 45 CFR 164.501: Definitions (treatment)
• 45 CFR 164.508: Uses and disclosures for which an authorization is required
• 42 CFR 2.11: Definitions (program, Part 2 program)
• 42 CFR 2.31: Consent requirements
• Federal Register: Confidentiality of Substance Use Disorder (SUD) Patient Records, final rule (February 16, 2024)
• 47 CFR 64.1200: Delivery restrictions (paragraph (a)(9)(iv), healthcare calls)
• 16 CFR 255.2: Consumer endorsements
• 15 U.S.C. 45: Unfair methods of competition unlawful

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