Subject: Request to Retain CPT 92507 Pending Review of Replacement-Code Structure, Valuation Concerns, and Implementation Readiness

I. Summary and Requested Relief

I respectfully request extraordinary reconsideration of the scheduled January 1, 2027 deletion of CPT 92507 (Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual) and its replacement by CPT codes 92654–92663.

CPT 92507 accounted for approximately 95% of Texas Medicaid of outpatient speech-language pathology claims in 2017. [Texas Health and Human Services Commission, February 28, 2017 IG Report, IG-17-010]. Other sources report greater than 80%. Its deletion therefore represents a fundamental restructuring of billing for individual outpatient speech-language pathology treatment.

I recognize the goals of improved coding specificity and recognition of treatment duration. Nevertheless, concerns regarding the replacement framework’s clinical classifications, reference services used in valuation, internal relative values, and payer implementation readiness warrant independent review before a change of this magnitude takes effect.

I request that the CPT Editorial Panel identify and consider any available extraordinary mechanism to retain CPT 92507 during that review, and coordinate with the appropriate AMA and CMS bodies regarding the associated valuation and payment implications. I recognize that the CPT Editorial Panel, RUC, and CMS have distinct responsibilities and that retention or deferral may require separate actions.

*All codes require direct, one-to-one patient contact

II. Gross Misalignment and Inappropriateness of Cross-Disciplinary Reference Selections

The valuation of the new 10-code timed SLP matrix (92654-92663) is invalid due to the selection of the reference crosswalk codes that lack clinical, operational, or behavioral parity with direct SLP intervention.

The Technician-Led Testing Anomaly: The RUC inappropriately crosswalked elements of the new face-to-face clinical treatment codes against untimed diagnostic testing codes designed for automated or technician-led operations. Testing procedures are diagnostic, analytical, and heavily automated; they do not simulate the intense, continuous cognitive and physical behavioral shaping required during an individual SLP treatment session. This choice artificially compresses the Work RVUs for the base 30-minute codes.

The “Patient-Absent” Time Code Contradiction: Even more egregious, the RUC crosswalked portions of the new face-to-face timed codes against historical benchmarks for timed services performed without the patient present (such as caregiver training). Outpatient SLP treatment requires continuous, direct, one-on-one intra-service patient contact. Benchmarking a highly specialized treatment discipline against a “patient-absent” administrative or counseling framework represents a fundamental failure of clinical tracking.

By utilizing reference codes that either do not require a qualified healthcare professional’s active presence or do not require the patient’s presence, the AMA has engineered an artificial devaluation of SLP services. This methodological error will decimate practice margins and systematically restrict access to care across the nation.

The Core Flaw: The new 10-code SLP matrix mandates intensive, direct, one-on-one patient engagement.

The Result: Utilizing a “patient-absent” administrative or distant counseling framework as a benchmark for intensive, live therapy undermines the validity of the RUC’s intensity/complexity scoring.

III. Violation of Cross-Disciplinary Procedural Standardization (Rank-Order Anomaly)

Proposed 2024 Medicare Physician Fee Schedule

The 2027 code structure violates a foundational principle of the CPT manual: codes must describe the procedure or intervention performed, not the patient’s diagnostic domain.

The AHP Standard: Physical Therapy (PT) and Occupational Therapy (OT) code sets categorize interventions by clinical procedure (e.g., therapeutic exercise, neuromuscular reeducation), regardless of whether the underlying pathology is neurological, orthopedic, or developmental.

The SLP Flaw: The new 10-cde SLP matrix shifts coding parameters to disorder domains (fluency, speech sound production, language, voice). The forces a dual-coding crisis when multiple overlapping disorders are addressed in a single session.

By basing codes on pathology rather than clinical methodology, the Panel, has created an acute structural anomaly that distorts relative value unit (RVU) parity across comparable AHP disciplines.

By indexing code to specific diagnostic domains (fluency, speech sound, language, voice), rather than the distinct clinical modalities, cognitive tasks, and procedural interventions performed by the clinician, the framework directly undermines the core mechanism of the Resource-Based Relative Value Scale (RBRVS). Under 42. U.S.C 1395w-4, wRVUs must reflect the relative resources, physician time, and intensity required to perform a procedure.

Defining codes by disorder domain improperly treats therapeutic interventions as if they were passive, automated diagnostic profiles (such as the flawed reference anchors CPT 92584 and 92651). This structural shift fails to account for the reality that the clinical intensity, behavior management, and cognitive labor of a therapy session are driven by the procedural modality utilized by the specialist, not the patient’s diagnostic classification. This architectural flaw creates an unsustainable billing model that forces clinicians to double-report diagnostic categories already captured via mandatory ICD-10 coding, violating basic administrative simplification tenets.

Given the scale of the transition, I am requesting a documented readiness assessment and a contingency plan to preserve continuity of claims processing and patient treatment.

IV. Requested Actions

1. Extraordinary CPT review: Determine whether an available extraordinary or corrective procedure permits retention or deferral of the scheduled deletion of CPT 92507, and provide the procedural requirements and timetable.
2. Transitional retention: If procedurally available, retain CPT 92507 as an active code for at least a 12-month transition period while the replacement structure is independently evaluated.
3. Coordinated valuation review: Refer the identified reference-service and internal-relativity questions to the appropriate RUC or specialty review process; consider a corrective survey if the evidence demonstrates a need.
4. Multidisciplinary clinical and operational assessment: Include practicing speech-language pathologists, coding experts, relevant rehabilitation professionals, and payer implementation representatives in a review of overlapping treatment, valuation assumptions, and claims readiness.
5. Revise replacement CPT codes that categorize intervention by clinical category rather than disorder domain.
6. Written procedural response: Identify which requested actions are within the CPT Editorial Panel’s authority, which require action by the RUC or CMS, and whether any relief can be effective before January 1, 2027.

V. Closing

The combined questions concerning clinical comparability, internal relativity, integrated treatment reporting, and implementation readiness warrant extraordinary scrutiny before CPT 92507 is permanently deleted. I respectfully request prompt consideration and a written response identifying the available procedural path.

Respectfully submitted,

[Contact name, credentials, and contact information]