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Dear CMS Medicare Physician Fee Schedule Team,

Although the official public comment window for the Calendar Year 2027 Physician Fee Schedule proposed rule closed on September 14, 2026, I am writing to submit critical cross-specialty evidence regarding an essential logical flaw in the proposed valuation of the ten new timed replacement codes for CPT 92507 (specifically the base codes 92654, 92656, 92658, 92660, and 92662). This structural inconsistency creates severe cross-specialty inequity and undermines CMS’s statutory mandate for internal relative value consistency.

I. Flawed Valuation Framework Against Untimed, Technical Benchmarks

The proposed Work Relative Value Units (wRVUs) for the new 30-minute initial speech-language pathology base codes—for instance, the 0.92 wRVU allocated to Fluency base code 92654—erroneously equate the intense clinical work of a highly trained, specialized professional to the valuation of an untimed diagnostic test that can be carried out by a technician.

Equating these two service profiles introduces a severe mathematical flaw:

  • Professional Cognitive Load: The 92507 replacement codes describe active, direct, face-to-face therapeutic interventions. They require a master's or doctoral-level practitioner to continuously evaluate performance, synthesize real-time data, and dynamically alter therapeutic techniques.
  • Technician-Led Diagnostics: Conversely, the benchmark untimed diagnostic codes reflect standard protocol administration, often performed by clinical staff or technicians without a Qualified Health Care Professional (QHP) actively directing the entire intraservice duration.

Compressing a face-to-face, expert-level therapeutic service into an RVU tier designed for technician-administered diagnostic testing severely undervalues the specialized, real-time medical decision-making inherent to speech-language pathology interventions.

II. Erroneous Parity with Non-Face-to-Face ("Patient Not Present") Codes

Furthermore, the proposed valuation relies on reference code comparisons where the patient is not present. This comparison fundamentally breaks down across CMS’s own established time and work frameworks:

  • By definition, non-face-to-face or patient-absent codes lack the immediate clinical risk, cognitive intensity, and behavioral management necessary to safely treat a live patient under a dynamic plan of care.
  • Isolating a clinician's face-to-face treatment time and matching its intensity to a passive, asynchronous review or an isolated technical calculation strips away the recognized value of specialized clinical interaction.

III. Systemic Distortion: Disorder Domain Ties vs. Procedure-Based Valuation

Compounding these errors is a fundamental structural departure from standard fee schedule mechanics. Across virtually all other outpatient services provided by a QHP (such as physical therapy, occupational therapy, or behavioral health), payment rates are tied directly to the clinical procedure or therapeutic modality performed, rather than the underlying disease state.

By tying the new 92654–92663 series rates strictly to isolated disorder domains (e.g., separating fluency from voice, or speech sound production from language), CMS has introduced a severe rank-order anomaly into the fee schedule:

  • This framework falsely implies that treating one communication disorder is inherently less intense or complex than another, reimbursing qualified clinicians differently for identical time spent.
  • It forces unequal valuations for overlapping clinical tasks, disregarding the fact that the professional work, behavioral management, and specialized cognitive effort required to conduct a 30-minute face-to-face intervention remain uniformly high across all communication domains.
  • It disrupts cross-specialty equity by penalizing speech-language pathology with a diagnostic-dependent tiering structure that is completely absent from peer physical medicine and rehabilitation codes.

IV. Request for Administrative Remedy Before the Final Rule

To prevent systemic underfunding of essential communication and cognitive therapies, I respectfully urge CMS to re-evaluate the cross-specialty references utilized during the RUC valuation process. The 30-minute base codes for the 92654–92663 family must be mapped to peer outpatient codes that explicitly require direct, face-to-face QHP professional time, are valued based on the procedure performed, and carry equivalent cognitive complexity.

Thank you for your review of this late-filed information and for your ongoing dedication to ensuring fair, data-backed payment equity across all healthcare specialties.

Respectfully submitted,

[Your Name]
[Your Title/Credentials, e.g., MS, CCC-SLP]
[Your Practice or Organization Name]
[Your Contact Information]

The Coalition will not stop advocating for Patient Access to Speech-Language Pathology Services and will not stop advocating to protect all Speech-Language Pathologists, no matter their practice setting.

We will continue to organize outreach to legislators and CMS and any other avenue that might change the trajectory of the new billing codes and practices for 2027.

When ASHA and the RUC committee surveyed providers to value these new codes, they mapped them against completely inappropriate medical reference benchmarks.

ASHA refuses to demand a halt to implementation; it isn’t an issue of “learning a new schedule,” it is an institutional failure to protect the basic economic valuation of SLP clinical labor.

During the dark period between open comment and finalization, our other options are contacting CMS through staff and energizing a Congressional inquiry.

Please consider sending the CMS email by using the button to the left.

The process works exactly as it does for the original ASHA email and the Response to ASHA email.

Feel free to email the Coalition at slppatientadvocacy@gmail.com if you have any issues with the emails or have concerns.

We must all work together to safeguard this invaluable profession and to advocate for those we serve.