Cracking the Code: Unlocking the Potential of Medical Codes for Food as Medicine
Photo courtesy of cottonbro studio
By Katie Ettman on June 19, 2025.
Every year, millions of Americans head to their primary care doctor for a checkup, go to a clinic to get their blood pressure checked, or walk into a pharmacy to pick up a prescription. What do all of these things have in common? A medical code— a combination of numbers (and sometimes letters) that represents a diagnosis, a healthcare professional’s labor, or a product. These codes, which are key elements of the technological infrastructure of modern healthcare, help patients get the services they need and ensure their providers get paid. And while hundreds of thousands of Americans receive food-based interventions like medically tailored meals and produce prescriptions every year, codes don’t yet exist to facilitate these life-improving healthcare services.
Instead, food as medicine providers are building work-arounds that parallel the traditional healthcare system. For example, community-based organizations are faxing individual invoices rather than submitting claims to the health plans for payment. Or in other instances, providers are adding modifiers to existing non-specific billing codes which means coding is not consistent across implementations.
To overcome this challenge, Fullwell partnered with Gravity Project, an open consensus collective dedicated to building data standards to address the social determinants of health, and a nationally representative Advisory Committee to launch Coding4Food. This community-led initiative’s goal is to secure new Healthcare Common Procedural Coding System (HCPCS) codes that represent the full spectrum of food-based interventions. By securing these new codes, the national healthcare ecosystem will not only be able to better deliver food as medicine services and reduce the administrative costs of billing, but also collect better data, using shared codes, that allows for improved analysis of the impact of food on health outcomes across states.
The project took place in two phases over the course of 2024 and 2025. In phase one, the Coding4Food Advisory Committee reviewed nearly 60 applications to fill 34 spots in three intervention-specific expert workgroups—medically tailored meals, medically tailored groceries and produce prescriptions. These three distinct workgroups were tasked with one key objective: clearly and concisely defining the service. For example, the definition needs to clearly articulate why a medically tailored meal is different from a home-delivered meal.
In addition, the project team completed seven key informant interviews with people who received different food-based services. Through these interviews, we learned the various ways patients access services, whether they liked the food provided, and key aspects of the program design that made the service more or less convenient. Quotes from these interviews, like the one below, were shared with the workgroups so they could keep recipient feedback top of mind while crafting the service definitions.
“They were going to deliver 14 [meals] but I don’t eat that many meals. Instead, I get 7 frozen meals and string cheese, energy bars, greek yogurt. The produce is fresh, milk and cereal and eggs all really good. Quality stuff.” – Medically Tailored Meal recipient
Quotes like the one above reminded the Medically Tailored Meals workgroup that their definition of a “meal” needed to be flexible because many individuals, particularly those struggling with chronic conditions, struggle to eat 3 standard size meals a day. To address this concern, the final definition states that a meal is an estimated 1/3 of the recommended dietary intake for a day. This could be fulfilled with a combination of prepared entrees and sides which can be broken apart throughout the day.
Bolstered by these insights, the workgroups crafted definitions over the course of months which were then shared on public calls hosted by Gravity Project every other week so that anyone interested in the process could share their feedback for integration into the final definition. Each of the workgroups were successful and finished crafting their respective definitions in November 2024.
The new, proposed definitions are:
Medically Tailored Meal: Meal, providing an estimated 1/3 of the recommended dietary intake(s), per therapeutic, evidence-based dietary specifications for conditions, prepared using natural foods*, assigned based on an assessment of the individual’s nutritional needs by a Registered Dietitian (RD) or other nutrition professional, intended for use in non-facility/home settings.
*Natural- nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food. (USDA)
Medically Tailored Groceries: Shelf-stable products (and produce and other perishables if able) designed to meet at least 1/3 of the comprehensive recommended intake for one person per week, based on a Registered Dietitian (RD) or other nutrition professional’s assessment of their nutritional needs and disease-specific, evidence-based tailoring as part of a therapeutic diet plan.
Healthy Groceries: Shelf-stable products (and produce and other perishables if able) designed to meet at least 1/3 of the comprehensive recommended intake per the US dietary guidelines for one person.
Includes all population guidance for limiting sugars, saturated fats, and sodium. Excludes alcoholic beverages. If appropriate, US Dietary guidelines are modified to meet disease-specific requirements.
Referencing the US Dietary Guidelines and the FDA standards of identity.
Modifier to represent the addition of perishables.
Produce Prescriptions: Fresh produce provision, which is all forms of produce defined in US dietary guidelines (e.g. fruits, vegetables, and legumes).
May also include canned, frozen, or dried produce consistent with WIC guidelines and FDA standards of identity. Excludes all forms of juices and nut butters.
One base unit equals one cup equivalent of produce per day per week (or USDA calculated lb/week equivalent); cup equivalents are aligned with US Dietary guidelines. Unit may be provided in cash value benefit (CVB) aligned with current USDA produce cost tables with adjustments for regional, local, or organic costs.
The base unit is multiplied to meet prescribed comprehensive recommendations for produce intake per person, or to align with program administrative requirements (e.g. monthly allocation of CVB.)
Once the definitions were complete the Gravity Project terminology team began drafting applications to the Centers for Medicare and Medicaid Services (CMS), the federal agency that oversees HCPCS, which were submitted in January 2025. After the submission to CMS there is a three-step process for review and adoption. First, CMS submits any questions or clarifications to the submitter to determine whether the applications will be brought to one of two annual HCPCS public review meetings which take place in May and November each year. If the applications make it through the public review meeting it moves to general public comment on the Federal Register before the ultimate rejection or acceptance.
In February, phase two expert workgroups were launched to define Kitchen & Cooking Supplies and Cooking Education. Similarly to phase one, these workgroups met over the course of months to define the interventions. Ultimately these two groups with input from recipients of these interventions came up with five distinct definitions:
Small Kitchen Appliances: New small kitchen appliances necessary for meal preparation to meet an individual’s nutrition and dietary needs. The aim is to ensure a set of necessary small appliances by addressing gaps after the assessment of existing appliances, an individual's needs (including adaptive appliances if required), and cultural and personal preferences.
Examples of necessary appliances include but are not limited to: Burner, Air Fryer, Pressure Cooker, Rice Cooker, Slow Cooker, Microwave, Toaster Oven, Food Processor, Hand Chopper, and Blender (*other additional appliances if appropriate after assessment).
Cost is understood to be base expense plus an agreed-upon administrative fee.
Large Kitchen Storage Appliances: Core basic large kitchen appliances to store food and medications. New large kitchen appliances necessary to safely store food and medications. The aim is to ensure a set of necessary large appliances by addressing gaps after the assessment of existing appliances and an individual's needs and preferences.
Examples of necessary appliances include, but are not limited to, refrigerators and freezers.
Cost is understood to be base expense plus an agreed-upon administrative fee.
Kitchen Tools: Core basic kitchen tools to prepare, consume, and store meals. New non-food cooking tools necessary for meal preparation, consumption, and storage to meet an individual’s nutrition and dietary needs. The aim is to ensure a set of necessary tools by addressing gaps after the assessment of existing supplies, an individual's needs (including adaptive tools if required), and their cultural and personal preferences.
Examples of necessary tools include, but are not limited to sharp knives, cooking and serving utensils, cooking and serving equipment, pots and pans, and tableware.
Note, appliances are not included.
Cost is understood to be base expense plus an agreed-upon administrative fee.
Cooking Education per 30 minutes: Cooking education, toward basic nutrition concepts and cooking skills development.
General nutrition concepts: what food items people should eat more of, less of, and why; portion and serving sizes; adaptations for cultural preferences; may include diet-related condition prevention and management.
Skill development: food procurement and storage (including cost per unit and how to maximize a dollar); food safety and safe food handling; using, creating, and modifying recipes; understand how to safely use tools (e.g. knife skills); cooking methods/techniques.
Culinary health counseling and coaching (e.g. motivational interviewing)
Curricula Requirements: evidence-based curricula with assessments recommended but not required; Professional: A multidisciplinary team is recommended but not required.
Our hope is that CMS will bring all nine applications for new medical codes to the November 2025 public meeting for review which will ultimately lead to acceptance in early 2026. Should CMS accept these new codes, it would pave the way for streamlined payment for service and improved data collection. Most importantly, though, these new codes would give health care providers the ability to more effectively and efficiently deliver food as medicine to millions of people each year.
