More Actionable Facts
ASHA Rejects the Proposed G-SLPP Code—The Coalition Believes Similar Valuation Concerns Apply to the 10 Proposed Speech-Language Pathology Treatment Codes
ASHA has formally requested that CMS reject the proposed HCPCS G-SLPP code and conduct a transparent, specialty-level review of speech-language pathology before issuing the final rule. The Coalition to Protect Patient Access to Speech-Language Pathology Services believes the same valuation concerns warrant a comparable review of the 10 proposed speech-language pathology treatment CPT codes that would replace CPT 92507.
The Coalition welcomes ASHA’s request and agrees that both proposals depart from the fundamental principle that healthcare services should be valued according to the resources required to furnish them, including provider time, technical skill, clinical judgment, mental effort, stress, and practice expense. While the proposed G-SLPP code combines bundled treatment with beneficiary age, the proposed replacement CPT codes combine timed treatment with disorder-specific payment rates. Although the methodologies differ, both shift payment away from the professional work performed by the speech-language pathologist.
The Coalition is particularly concerned that the proposed CPT valuations create payment relationships that appear inconsistent with the Resource-Based Relative Value Scale (RBRVS), under which relative values are intended to reflect the resources required to provide a service. Medicare payment should be based on the work involved in delivering skilled treatment—not on the patient’s diagnosis or disorder category alone.
Relative Value Units (RVUs) are intended to reflect provider work, including professional time, technical skill, mental effort, clinical judgment, stress, and practice expense. The Coalition believes the proposed valuation of the 10 replacement CPT codes creates significant inconsistencies in the relative ranking of services.
One of the clearest examples involves voice treatment. Voice services may be provided pre-surgery, post-surgery, or as an alternative to surgery, for lesion formation, serious medical conditions including upper airway respiratory conditions and other conditions including spasmodic dysphonia. Despite the complexity and clinical importance of these services, the proposed valuation places voice treatment below several other treatment categories, creating a rank-order anomaly that appears inconsistent with the professional resources required to furnish the service.
These valuation concerns extend beyond the voice treatment category. The proposed payment hierarchy assumes that speech-language pathology treatment domains require substantially different levels of professional work. In practice, speech-language pathologists routinely address multiple communication impairments during the same treatment session. Treating concurrent speech and language disorders in a single treatment session does not increase the professional time, technical skill, clinical judgment, mental effort, stress, or practice expense required to provide skilled care.
When CPT evaluation codes 92521, 92522, 92523, and 92524 replaced CPT 92506 in 2014, their relative values reflected the professional time and resources required to perform each evaluation based upon recognized standards of care—not the patient’s disorder category. The Coalition believes the same valuation principles should apply to treatment services. Evaluation methodologies should not be used to justify differences in therapeutic treatment valuation based primarily on disorder category.
The value of a healthcare service should:
1. Reflect the actual resources required to furnish the service, including professional time, technical skill, clinical judgment, mental effort, stress, and practice expense.
2. Preserve logical rank-order relationships that are consistent with Resource-Based Relative Value Scale (RBRVS) principles.
3. Avoid payment structures that could create unintended barriers to patient access by establishing reimbursement differences based primarily on disorder category.
Although treatment frequency varies considerably among communication disorders, the professional resources required to provide a 30-minute treatment session—including provider time, technical skill, mental effort, clinical judgment, stress, and practice expense—do not vary solely because of the communication disorder being treated.
ASHA has also stated that the proposed valuation of the G-SLPP code—$66.34 for an assumed 60 minutes of personally performed treatment—could reduce payment to a level that threatens beneficiary access to care. The Coalition agrees and believes similar payment disparities among the proposed replacement CPT codes may likewise create unintended barriers to medically necessary speech-language pathology services.
The Coalition supports the transition to time-based treatment coding. Under the current untimed CPT 92507, reimbursement may be the same regardless of whether treatment lasts 15, 30, or 45 minutes. A time-based payment structure more accurately recognizes the professional time required to deliver skilled care.
Treatment payment should therefore reflect the qualified provider’s professional work, clinical judgment, and time rather than assigning different reimbursement rates based primarily on disorder category. Speech-language pathology services should be valued consistently with the principles used throughout Medicare for physicians, physical therapists, occupational therapists, and other qualified healthcare professionals.
The Coalition therefore supports ASHA’s request that CMS reject the proposed G-SLPP code and to delay implementation of the 10 proposed speech-language pathology treatment codes until their valuation methodology has undergone a transparent, specialty-specific review and the identified rank-order anomaly has been resolved.
CMS is currently accepting public comments before issuing its final rule. This is the profession’s opportunity to help ensure that Medicare payment policies support both high-quality care and continued patient access to medically necessary speech-language pathology services.
Please share this information with colleagues, employers, state associations, legislators, and patient advocacy organizations, and encourage others to speak out. A strong, unified response from the speech-language pathology community will help ensure these proposals receive the careful review they deserve before implementation.
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The proposed 2027 Medicare Physician Fee Schedule would replace CPT code 92507 with ten new speech-language pathology treatment codes. The proposed valuation reimburses qualified speech-language pathologists differently based on the patient’s disorder rather than provider time, qualifications, or practice expense.
This change creates significant concerns for patients, providers, and payers and warrants delaying implementation until reimbursement accurately reflects provider time and implementation systems are prepared.
Key Findings
CPT 92507 currently accounts for approximately 95% of outpatient speech-language pathology claims, creating a widespread risk of reimbursement disruption during implementation.
Reimbursement would vary by communication disorder despite comparable provider qualifications, professional time, clinical intensity, and practice expense.
Proposed reimbursement reductions range from 4.6% to 34.41%, depending on the disorder treated.
Pediatric communication disorder services would experience an estimated 11.6% reduction in reimbursement.
Lower reimbursement creates incentives to reduce treatment of lower-paying disorders, threatening patient access to care.
Medicaid programs and commercial insurers are unlikely to complete implementation of the new coding structure before the January 1, 2027 effective date.
Why the Proposed Valuation Is Concerning
Reimbursement Is Based on Diagnosis Rather Than Provider Time
Qualified speech-language pathologists meet the same education, licensure, and scope-of-practice requirements regardless of the communication disorder being treated. The professional time, clinical expertise, practice expense, and malpractice expense required to provide treatment are substantially comparable across communication disorders.
Despite these similarities, the proposed fee schedule assigns different reimbursement rates based solely on diagnosis. This represents a significant departure from reimbursement methodologies used for comparable rehabilitation professions, where payment is primarily tied to professional time rather than the condition being treated.
Reduced Access to Care
The proposed payment methodology creates financial incentives to limit treatment of lower-reimbursed disorders, including fluency disorders, voice disorders, and many pediatric communication disorders.
Providers who devote equivalent professional time to these services would receive substantially lower reimbursement than providers treating other communication disorders. Over time, these payment disparities may reduce provider participation and limit patient access to medically necessary speech-language pathology services.
Financial Impact on Outpatient Practices
Many outpatient speech-language pathology providers already operate on narrow financial margins. Proposed reimbursement reductions of up to 34.41% threaten the financial sustainability of practices serving lower-reimbursed patient populations.
Because reimbursement differences are tied to diagnosis rather than provider effort or cost, practices specializing in fluency, voice, language, and pediatric communication disorders would be disproportionately affected.
Estimated Financial Impact
The proposed reimbursement methodology creates significant payment differences for services requiring comparable provider qualifications, professional time, and practice expense.
Estimated Annual Medicare Reimbursement*
(Based on one full-time speech-language pathologist providing 30 hours of direct patient care per week for 46 weeks.)
Primary Treatment Focus *Estimated Annual Reimbursement
Speech Sound Disorders $182,187.60
Speech Sound & Language Disorders $197,588.40
Fluency Disorders $150,585.60
Voice, Upper Airway & Resonance Disorders $151,358.40
Language Disorders $137,779.20
Pediatric Communication Disorders (G-Code Equivalent) $91,093.80
These estimates demonstrate substantial reimbursement differences that are driven by diagnosis rather than provider time or qualifications. Practices serving fluency, voice, language, and pediatric populations would receive significantly lower reimbursement despite providing comparable professional services.
Implementation Readiness
Successful implementation requires more than establishing Medicare payment rates. State Medicaid programs and commercial insurers must also adopt, value, and operationalize the new treatment codes.
Several implementation challenges warrant delaying the effective date:
CPT 92507 currently accounts for approximately 95% of outpatient speech-language pathology claims, creating a widespread risk of reimbursement disruption during implementation.
State Medicaid agencies require time to complete rulemaking, fee schedule updates, and systems changes.
Commercial insurers must revise payment policies, claims processing systems, contracts, and provider education.
Providers will require time to update electronic health records, billing systems, documentation workflows, and staff training.
Implementing the new codes before payer systems are fully prepared increases the likelihood of claim denials, payment delays, administrative burden, and interruptions in patient care.
Why a Delay Is Appropriate
Delaying implementation would allow CMS and stakeholders to:
Reevaluate reimbursement to better align payment with provider time, clinical expertise, and practice expense.
Reduce unintended incentives that may limit access to lower-reimbursed communication disorder services.
Provide Medicaid programs and commercial insurers sufficient time to implement the revised coding structure
Support a smoother national transition while minimizing disruptions for patients, providers, and payers.
Requested Action
We respectfully request that CMS delay implementation of the revised speech-language pathology treatment codes until:
Reimbursement more accurately reflects provider time, professional qualifications, and practice expense.
The potential impact on patient access has been fully evaluated.
State Medicaid programs and commercial insurers have sufficient time to implement the new coding structure.
Providers can transition to the revised coding system without unnecessary disruptions to patient care.
Delaying implementation will help ensure that payment policy supports equitable access to medically necessary speech-language pathology services while allowing adequate time for a successful nationwide implementation.
CALL TO ACTION
This is a call to STAND UP, SPEAK OUT, and form a coalition to highlight the devastating consequences of the revision and valuation of 95% of the services provided by SLPs and to demand a delay in CMS implementation of the changes to CPT 92507.
According to the AMA, deleted CPT code 92507, currently used to report a wide range of speech-language pathology services, was overly broad and lacked the specificity needed to reflect modern clinical practice. The AMA stated that the code did not accurately capture the distinct clinical needs and therapeutic approaches required. The code will be replaced by ten new Category I codes covering fluency, speech sound production, language, and voice disorders through separate time-based base and add-on codes.
The revised CPT codes proposed by CMS re-values services currently billed under CPT 92507 by creating a direct variable payment rate based solely on a patient’s disorder, despite identical provider time, identical clinical settings, and services delivered by equally qualified, licensed, enrolled healthcare providers.
The proposed rate structure creates an unjust and negative financial impact on providers treating specific patient populations. In addition, it incentivizes providers to treat only certain disorders, to the detriment of patients.
The impact will be felt not only by you and me, but by the entire speech-language pathology profession and, most importantly, by the patients with communication disorders whom we serve.
The revision of the frequently used CPT code 92507 was reportedly based on concerns regarding overutilization. Multiple issues no doubt contributed to the marked increase in overutilization.
Key Facts
· CPT 92507 represented just 0.0129% of Medicare Part B expenditures in 2022.
· The number of beneficiaries receiving CPT 92507 increased by 84% between 2017 and 2022.
· The number of enrolled Medicare Part B providers billing CPT 92507 increased by 123.65%.
· Reimbursement rates did not increase. In fact, the 2022 Medicare allowable payment was lower than it was in 2014 ($61.82), despite increasing provider costs.
· Telehealth expansion during and after COVID-19 significantly increased access to care.
· Multiple state Medicaid programs directed providers to bill multiple units for CPT 92507, contrary to National Correct Coding Initiative (NCCI) edits.
Additionally, beginning in 2018, clinicians were directed to bill treatment for active dementia using CPT 92507. “Active dementia” refers to underlying language impairment identified following a comprehensive speech-language assessment (CPT 92523). In contrast, CPT 97127 (non-Medicare) or the applicable Medicare G-code is used following a cognitive assessment (CPT 96125) for patients with medical diagnoses involving cognitive impairment, such as traumatic brain injury (TBI) or concussion.
Overutilization often occurs because claims are not consistently reviewed for medical necessity or adherence to established standards of care and best practices.
None of these issues are addressed by the coding revision or the proposed disparate payment structure.
The concern regarding a lack of specificity in in CP 92507 is shown to be without merit based on parallels in physician billing. This is illustrated in the code descriptions below.
Treatment for communication disorders (speech, voice, fluency, communication, language, and auditory comprehension) cannot be captured in discreet disorder-driven codes. Communication is the result of choregraphed, sequenced motor movement events governing respiration, phonation, resonance, and articulation triggered by complex neural circuitry of phoneme selection, motor sequencing, lexical selection, thought formation and intent, and purpose governed by multiple feedback and sensory processes that are best captured by broad time-based codes similar to physicians’ codes. Medical necessity for SLP services is carried under the ICD-10 diagnosis codes consistent with all other healthcare providers.
In July 2026, CMS accepted the proposed work Relative Value Units (RVUs) and direct practice expense values for all ten new SLP treatment codes and proposed a new pediatric code (G-SLPP).
CMS determines Relative Value Units (RVUs) by assessing three core components:
· Physician work (time and intensity)
· Practice expense (overhead and staffing)
· Malpractice expense (insurance)
A revision that quantifies provider time would be more equitable and consistent than the proposed disorder-specific payment disparities.
Conclusion and Call to Action
The proposed fee schedule is inconsistent with other reimbursement methodologies and may reduce access to care for certain patient populations.
The inequitable rate formularies are additionally concerning because an insurance executive from the largest healthcare and health insurance provider in the United States served as a member of the AMA RUC Health Care Professionals Advisory Committee (HCPAC), which reviews reimbursement recommendations for ancillary services, and also served on the AMA S141 panel. This introduces financial stakeholder influence into what should be an expert clinical advisory process.
The disparate payment rates ensure that SLPs are not treated as equal stakeholders within the healthcare system.
Given the impact on all of us—not just you and not just me—STAND UP. SPEAK OUT. Use the power of communication, the very power we strive to provide to those who cannot communicate effectively on their own.
Join the coalition to delay implementation of the revised valuation of CPT 92507.
Contact your Congressional representatives and urge them to exercise their oversight responsibilities regarding Medicare, Medicaid, and CMS to address systemic barriers to patient access and structural inequities in reimbursement.
Financial Comparison:
Physician Codes For Established Patients
(2026 Medicare National Averages)
The longer a physician spends on a patient visit, the higher the corresponding code level and reimbursement.
CPT Code
Required Time Window
National Medicare Payment (Non-Facility)
99212
10–19 minutes ~$59.45
99213
20–29 minutes ~$95.19
99214
30–39 minutes ~$135.61
CPT 99212: Level 2 Established Patient Visit
· Definition: Office or other outpatient visit requiring straightforward medical decision-making (MDM) or at least 10 minutes of total provider time on the encounter date.
· Clinical Scenario: The patient presents with a single, minor, self-limited, or reversible problem.
· Examples: A healthy patient presenting for a simple wart removal or a routine refill visit for a single, completely stable condition requiring no medication changes.
CPT 99213: Level 3 Established Patient Visit
· Definition: Office or other outpatient visit requiring low-complexity MDM or at least 20 minutes of total provider time.
· Clinical Scenario: Stable chronic illnesses or uncomplicated acute problems.
· Examples: A well-controlled diabetic patient presenting for routine follow-up or a patient with a minor infection requiring standard prescription antibiotics.
CPT 99214: Level 4 Established Patient Visit
· Definition: Office or other outpatient visit requiring moderate-complexity MDM or at least 30 minutes of total provider time.
· Clinical Scenario: Chronic conditions that are progressing or poorly controlled, or new systemic problems requiring an extensive diagnostic workup.
· Examples: Managing a patient with hypertension and diabetes where both conditions are uncontrolled and medication adjustments are required.