Formal Complaint and Request for Valuation Deferral
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Formal Complaint and Request for Valuation Deferral
To: The Chair, AMA/Specialty Society RUC
Date: October 12, 2026
Subject: Methodological Flaws in Reference Code Selection for the 2027 Timed Speech-Language Pathology Treatment Matrix (92654-92663)
Statement of Complaint
This formal complaint is submitted to challenge the structural integrity and validity of the Work Relative Value Unit (wRVU) recommendations for the new 10-code times SLP maxtrix scheduled for January 1, 2027.
The survey and valuation process utilized grossly inappropriate reference crosswalk codes that completely lack clinical, operational, or behavioral parity with direct, face-to-face outpatient SLP intervention. By anchoring highly skilled behavioral treatments to completely unrelated service frameworks, the RUC has engineered an artificial devaluation of SLP services that threatens the entire healthcare delivery infrastructure for vulnerable populations.
| New SLP Code | Treatment | Comparator Codes Used in Code Valuation |
|---|---|---|
| 92654 | Fluency (30 min) | 92584; 97550 |
| 92656 | Speech sound (30 min) | 92584; 92651; 97550 |
| 92658 | Language (30 min) | 92584; 97550 |
| 92660 | Speech sound and language (30 min) | 92584; 92651; 97550 |
| 92662 | Voice (30 min) | 92584; 92651; 97550 |
*All codes require direct one-to-one contact
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 selectin 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 family psychotherapy or care coordination overviews). 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.
Violation of Cross-Disciplinary Procedural Standardization (Rank-Order Anomaly)
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 procedure codes describe intervention performed by the provider rather than anatomy or specific functional impairment being treated.
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 (RBVS). 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 clinician to double-report diagnostic categories already captured via mandatory ICD-10 coding, violating basic administrative simplification tenets.
Actionable Demands & Remedies
To preserve the scientific integrity of the RUC valuation process and protect the billing infrastructure of outpatient therapy, I request the following actions:
- Immediate Deferral of Valuation Recommendation: The RUC must formally request that CMS defer acceptable of the proposed wRVU values for codes 92654 through 92663 for the 2027 payment year.
- Re-instate CPT Code 92507 as an active, valid code for a minimum 12-month transition period.
- Re-Survey Mandate with Appropriate Clinical Peers: The RUC must initiate an emergency re-survey utilizing true clinical peer codes – specifically, timed procedural codes from adjacent Allied Health Professional (AHP) disciplines that require continuous direct face-to-face clinical intervention.
- Execution of a Joint Multi-Disciplinary Audit: Establish an immediate auditing panel to reconcile the rank-order anomalies introduced by this flawed reference selection.
The current recommendations are built upon an invalid foundation. I request an immediate hearing or formal administrative response ahead of the finalize Medicare Physician Fee Schedule.
Respectfully submitted,
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Update and Need For Continued Advocacy
Fix SLP has been able to meet directly with CMS staff and present the results of the SPEAK Project, an economic business analysis to protect the future sustainability of outpatient and private SLP practices, against declining Medicare rates. Well done!
We are sure the smoking guns issues of inappropriate reference selections, rank-order anomalies and disorder domains were discussed as well.
RBRVS overview requires CPT codes to define what the provider does (the procedure) not what the patient has (the diagnosis). The adoption of the proposed fee schedule will violate the statutory relative value units as it creates an “unconstitutional diagnosis track.”
CMS has a few options to address issues created by the replacement CPT codes given that the AMA is the only entity with authority over CPT codes.
The best and most direct option is the retraction of the deletion of CPT 92507.
We do not need to worry that these emails are not unique. The concerns are the same, no matter who sends the email. It is a numbers game from here on out.
We need to follow up with massive pushback. Contacting the CMS and AMA directly are one of the few courses of action that can be taken during the “blackout period.”
The route to retraction of CPT Code 92057 deletion would have been easier if initiated by our professional association.
However, ASHA has now explicitly confirmed that it:
Supports the RUC-recommended values for all ten replacement codes.
Will not request a delay in implementation.
Will not pursue a new survey or renewed valuation review based on the concerns submitted.
Does not consider the absence of final NCCI edits sufficient justification for a delay.
Intends to focus on implementation education rather than seeking changes to the proposed valuations.
Will not provide additional individualized responses to substantially similar requests.
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.
Violation of Cross-Disciplinary Procedural Standardization (Rank-Order Anomaly)
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 procedure codes describe intervention performed by the provider rather than anatomy or specific functional impairment being treated.
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 (RBVS). 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 clinician to double-report diagnostic categories already captured via mandatory ICD-10 coding, violating basic administrative simplification tenets.
We do not need to worry that these emails are not unique. The concerns are the same; violation of established methodology and rulemaking guidelines. It is a numbers game from here on out.
We need to follow up with massive pushback. Contacting the CMS and AMA directly are one of the few courses of action that can be taken during the “blackout period.
Every email sent to AMA and CMS immediately exposes the national association’s betrayal of its vision : “Making effective communication a human right accessible and achievable for all,” and its member-centric core value, “Dedicated to the needs of members and the public.”
Numbers matter!