EMAIL ASHA — IT TAKES LESS THAN A MINUTE

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I am writing as I believe the ASHA is currently falling short of its core mission to effectively support its professional members and advocate for individuals with communication disorders.

To that end, I call for the ASHA to request a delay in the implementation of the 10 new domain-specific, timed CPT codes (92654 through 92663) and the G-SLPP code set to replace the deleted CPT 92507 on January 1, 2027, and if unsuccessful, submit an immediate proposal to:

• Petition for a RUC Refinement Cycle: Initiate a formal request to the AMA RVS Update Committee (RUC) and flag codes 92654-92663 as “Potentially Misvalued.”
• Deploy a Corrective Time-and-Motion Survey: Re-survey the membership using clinical scenarios that accurately capture the intense, face-to-face nature of these sessions to decouple professional Work RVUs from baseline office overhead calculations.

While the intent to modernize reporting through timed units is understood, the resulting framework introduces a dangerous regulatory precedent: unequal reimbursement rates for identical provider time, determined solely by the patient’s diagnosis. Furthermore, the underlying survey methodology incorrectly presumes a “passive patient” or “low intensity” environment, ignoring the reality of direct, intense provider interventions.

This legacy code deletion and unbundling of CPT 92507 affect 95% of outpatient speech-language pathology claims, creating a widespread risk of reimbursement disruption and systemic billing collapse.

All new CPT codes are to be implemented January 1 of the following year after their adoption, but code changes rarely have this potential widespread impact. The legacy code CPT 92507 will be deleted January 1, 2027. Clearinghouses will not process claims containing deleted codes.

NCCI edits from CMS have not been published regarding billing of multiple base codes of the replacement code set. While some clinicians believe they will be able to bill multiple base code (i.e., code stacking), this frequently triggers flags for audit.

Medicare rates are a benchmark for Medicaid and commercial rates. These changes will affect every SLP, no matter the setting.

State Medicaid rates are generally 55% to 75% of the Medicare benchmark. Commercial carriers generally do not negotiate rates with individual practitioners and are not legally bound to do so. This means that the Medicare benchmark rates impact reimbursement standards for all types of insurance. The lower unequal reimbursement rates tied to communication disorder rather than therapist time reflected in the new CPT codes will have widespread impact.

Unlike physicians, SLPs are not legally defined as eligible to file a Medicare opt-out affidavit and cannot take cash or private pay for a Medicare or Medicaid beneficiary for a covered service. Over 47% of Americans are covered by Medicare or Medicaid.

The impact of the drastic rate reductions, the deletion of this most widely used legacy code, and implementation risks of the 10 new proposed replaced codes cannot be overstated.

The ASHA seems to recognize the methodology flaw in the proposed G-SLPP code, but has not acknowledged the same for the 10 replacement CPT codes.

The Core Valuation Flaw: Diagnosis-Driven Inequality

Under the approved Medicare Physician Fee Schedule (MPFS) framework, a flat, uniform professional unit value has been discarded. Instead, a minute of direct provider time is valued unevenly across clinical specialties. For example, 30 minutes spent in treatment of a fluency disorder (92654) is valued lower than 30 minutes spent in treatment of a speech sound production disorder (92656), despite requiring the same amount of intense, active clinical intervention from the therapist. By baking historical Practice Expense (PE) RVU imbalance directly into the base work RVUs, the professional time of SLPs who are ASHA members has been devalued based entirely on disorder domain.

Mischaracterization of Clinical Intensity

The current RVU allocation strongly implies that the provider is a passive participant or managing a device rather than administering continuous, highly demanding therapeutic intervention. Tying the rate to the diagnosis rather than the provider’s operational time effectively penalizes clinicians handling complex cases within lower-paying domains. It will force private practices and outpatient facilities to select specialties based on financial incentives.

New replacement speech therapy codes have disproportionate practice expense (PE) relative to physician work (wRVU) values because of how the Relative Value Scale Update Committee (RUC) calculated overhead versus direct provider time for specialized, time-based interventions.

The disproportionate practice expense will trigger a large loss of income to providers if the Multiple Procedure Payment Reduction (MPPR) is applied. The reduction is much greater for speech therapy compared with other therapies, including PT, due to greater percentage of the payment attributed to the practice expense (PE).

The Overall Impact

For the proposed replacement speech therapy codes, the practice expense (PE) proportion constitutes a massive portion of the reimbursement rate, greater than other therapies. Industry impact analyses from professional SLP billing advocates indicate that when a 30-minute secondary base code undergoes adjustment due to the MPPR as a secondary procedure, its total reimbursement drops by an estimated 34% to 38% compared to billing it alone. Conversely, the MPPR for physical therapy codes average 12% to 15% for specific units due to the smaller portion of RVU accorded to the PE.

Summary

The Centers for Medicare & Medicaid (CMS) has proposed a fundamentally flawed valuation structure for the new family of domain-specific, timed speech-language pathology (SLP) CPT codes designed to replace CPT 92507 (treatment of speech, language, voice, communication, and/or auditory processing disorder, individual). By selecting reference crosswalks that utilize highly unrelated diagnostic codes where the patient is a passive participant or entirely absent. Severe rank order anomalies were introduced to the code family.

Any SLP procedure formally under the scope of CPT 92507 cannot exist without the dynamic, active, face-to-face interaction between the therapist and the patient and are inherently human-centric. To anchor a highly intensive face-to-face session against a benchmark where the patient’s physical presence is secondary – or completely unnecessary – is a structural failure that devalues direct clinical care.

The reliance on these passive reference codes to establish the value of the codes replacing CPT 92507 directly contradicts the guidelines of the American Medical Association (AMA) Relative Value Scale Update Committee (RUC) and creates systemic rank order anomalies.

A review completed before restructuring and re-valuation of the legacy code revealed that the increased utilization stemmed, in part, from program integrity issues.

The transposition of the legacy code to the new CPT code revisions and the use of G-SLPP do not address the catalyst for revisions of the legacy code.

Immediate and Long-Term Action Required

With the hard deletion of 92507 arriving on December 31, 2026, our clinics must absorb these operational disruptions immediately. If not delayed and the 2027 rollout can no longer be halted, our national association must take responsibility for this flawed survey design and aggressively pursue administrative remedies.

In addition to the request for the ASHA to seek immediate delay in implementation, I formally request that the association immediately commit to the following steps:

• Petition for a RUC Refinement Cycle: Initiate a formal request to the AMA RVS Update Committee (RUC) and flag codes 92654-92663 as “Potentially Misvalued.”
• Deploy a Corrective Time-and-Motion Survey: Re-survey the membership using clinical scenarios that accurately capture the intense, face-to-face nature of these sessions to decouple professional Work RVUs from baseline office overhead calculations.

Please feel free to reply to this email to discuss this further.

Sincerely,
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