Formal Section 515 Request for Correction to CMS

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EMAIL Formal Section 515 Request for Correction to CMS Now

Re: Formal Request for Correction Under Section 515 of Public Law 106-554 — Valuation of CPT Codes 92654–92663 Replacing CPT 92507

Dear CMS Information Quality Officer:

I. Executive Summary and Formal Request

I hereby submit this formal Request for Correction under Section 515 of the Information Quality Act and applicable HHS and CMS information-quality guidelines, challenging the accuracy, objectivity, and clinical representativeness of information supporting the proposed valuation of the ten new speech-language pathology (SLP) treatment codes, CPT 92654–92663, scheduled to replace CPT 92507 on January 1, 2027.

The valuation framework relies upon reference services that may not adequately represent the professional time, skill, clinical judgment, treatment intensity, and resources required for continuous, direct, one-on-one speech-language pathology intervention. These concerns raise questions about the reliability of the resulting relative values and the potential consequences for patient access.

I request an expedited information-quality review, correction or clarification of the disputed valuation information, and consideration of delaying implementation until the identified deficiencies have been adequately examined.

II. Identification of Disputed Information and Clinical Comparator Codes

The disputed information concerns the clinical reference services, work relative value units (wRVUs), and valuation assumptions supporting the proposed payment rates for CPT codes 92654–92663 in the Calendar Year 2027 Medicare Physician Fee Schedule.

The following table identifies comparator codes associated with the five 30-minute base treatment codes, as reported in the AMA/Specialty Society RVS Update Committee (RUC) Health Care Professionals Advisory Committee (HCPAC) Review Board Summary of Recommendations, January 2026, Speech-Language Pathology Services – Tab 27B.

New SLP code	Treatment domain	Comparator codes identified
92654	Fluency (30 minutes)	92584; 97550
92656	Speech sound production (30 minutes)	92584; 92651; 97550
92658	Language (30 minutes)	92584; 97550
92660	Speech sound and language (30 minutes)	92584; 92651; 97550
92662	Voice (30 minutes)	92584; 92651; 97550

The repeated selection of these reference services across all five base codes raises a fundamental question: Were the clinical activities and professional resources represented by these comparators sufficiently similar to direct speech-language pathology treatment to support accurate and objective relative valuations?

1. CPT 97550 — Caregiver Training

CPT 97550 describes caregiver training without the patient present. Although caregiver training requires professional knowledge and skill, it is clinically distinct from direct, one-on-one speech-language pathology intervention. Individual SLP treatment requires continuous patient engagement, real-time assessment, therapeutic intervention, behavioral shaping, and modification of treatment strategies in response to patient performance.

I request that CMS examine whether the use of caregiver training without the patient present as a reference service adequately accounts for these differences in professional work, clinical intensity, and resource requirements.

2. CPT 92584 and CPT 92651 — Diagnostic Testing

These codes describe diagnostic procedures rather than sustained therapeutic intervention. Their clinical activities, procedural requirements, and patterns of professional involvement differ from the continuous, interactive treatment provided during individual SLP sessions.

The concern is not that diagnostic testing lacks clinical value or professional expertise. Rather, the work associated with performing and interpreting a diagnostic procedure may differ substantially from the sustained clinical decision-making, active intervention, and patient engagement required throughout a 30-minute, one-to-one direct, treatment encounter.

I request that CMS examine whether these untimed diagnostic reference services, one of which can be carried out by a technician, accurately represent the professional work associated with the new 30-minute SLP base treatment codes and whether their selection contributed to an understatement or inconsistent valuation of clinical resources.

3. Repeated Comparator Selection Across Treatment Domains

The table identifies CPT 92584 and CPT 97550 as comparators for all five 30-minute base codes, with CPT 92651 additionally identified for three codes. This repeated use warrants examination of the underlying clinical rationale and valuation methodology, particularly because the resulting payment values differ among disorder domains despite comparable treatment durations and professional qualifications.

I request that CMS determine whether the comparator selection and supporting information accurately reflect the clinical resources required for direct, one-to-one 30-minute SLP intervention and whether any resulting valuation inconsistencies warrant correction.

The central concern is not simply that reimbursement may be inadequate. It is that the information supporting the relative values may not accurately represent the professional work and resources required to perform the services being valued.

III. Structural Inconsistency and Rank-Order Concerns

The replacement framework establishes different reimbursement values for services furnished by the same licensed professional during comparable periods of direct patient contact, based upon the disorder domain being treated. Speech-language pathology treatment requires the integration of professional knowledge, clinical judgment, skilled intervention, and continuous patient engagement.

Although individual encounters may differ in complexity and intensity, the proposed domain-specific valuation differences raise questions about whether equivalent professional time, skill, clinical judgment, and practice resources have been consistently recognized. These disparities warrant examination for potential internal relative value inconsistencies and cross-specialty rank-order anomalies under the Resource-Based Relative Value Scale.

Other rehabilitation disciplines utilize time-based procedural codes that reflect the therapeutic intervention performed. CPT 97110, for example, describes therapeutic exercises by the clinical service rather than assigning separate codes according to the patient’s underlying neurological, orthopedic, or developmental diagnosis, body anatomy or functional limitation. I request that CMS examine whether direct-care rehabilitation services such as CPT 97110 provide more clinically appropriate reference points for evaluating professional time and treatment intensity.

The issue is not whether every treatment service must receive identical reimbursement. Differences in relative values should be supported by documented differences in the resources required to perform the services, not merely by diagnostic classification.

• Shifting the 92507 replacements (92654–92663) into "disorder domains" (e.g., coding specifically for an aphasia domain vs. an articulation domain rather than the act of speech-language therapy)
• The Chronological Distortion: 30 minutes of face-to-face provider time spent treating a stuttering or dysphonia disorder does not require substantially less physical/mental effort, time, and professional skill than 30 minutes spent treating an articulation or speech sound language disorder.
• The Reference Code Contradiction: Because the wRVU values were developed using mismatched, patient-absent, untimed diagnostic reference codes, a mathematical distortion was generated. This creates a statutory conflict with 42 U.S.C. § 1395w-4, which mandates that work units correspond directly to the actual provider resources consumed during the procedure and creates an Incontestable Rank Order Anomaly.

In Medicare fee scheduling, a rank order anomaly occurs when Code A requires equal or greater intensity and resource utilization than Code B, yet Code B is paid significantly more.

CPT Code Category (Initial 30 Min)	Provider Time Block	Valuation Status	Defalcation Per 30-Min Unit
Speech Sound Production (92656)	30 Minutes	Baseline / Higher Value	$0.00 (Reference standard)
Speech Sound Production Disorder and Language Comprehension and Expressive Disorder	30 Minutes	Baseline / Higher Value	$0.00 (Reference standard)
Fluency / Stuttering (92654)	30 Minutes	Arbitrarily Discounted	-$17.04
Voice / Resonance (92662)	30 Minutes	Arbitrarily Discounted	-$16.75

This structure fails the "arbitrary and capricious" test under the Administrative Procedure Act (APA). There is no peer-reviewed time or intensity study demonstrating that treating a severe vocal cord pathology or complex stuttering pattern for 30 minutes costs a provider exactly $16.75/$17.04 less in objective cognitive labor per half-hour than treating a patient with a concurrent articulation and language disorder for 30 minutes or exactly $11.17/$11.49 less in objective cognitive labor per half-hour than treating a patient with an articulation disorder.

The issue is not whether every treatment service must receive identical reimbursement. Differences in relative values should be supported by documented differences in the resources required to perform the services, not merely by diagnostic classification.

IV. Potential Impact on Medicare and Medicaid Beneficiaries

CPT 92507 has historically represented a substantial majority of outpatient individual speech-language pathology treatment claims. Its replacement therefore affects a significant portion of the profession’s clinical and billing activities.

If the proposed valuations are based on insufficiently representative clinical information, the resulting payment disparities may place financial pressure on independent outpatient practices, particularly those serving patients requiring intensive or ongoing treatment. Potential consequences include reduced Medicare participation, limitations on treatment availability, and diminished access to medically necessary services for individuals with stroke, traumatic brain injury, neurodevelopmental disorders, and other communication impairments.

I am particularly concerned that implementing a valuation structure based on insufficiently representative information could create avoidable disruptions in patient access before the underlying methodological concerns are resolved.

V. Requested Corrections and Administrative Actions

Pursuant to Section 515 and applicable HHS and CMS information-quality guidelines, I respectfully request that CMS:

1. Conduct an expedited information-quality review of the clinical reference services, valuation assumptions, and supporting information used to establish relative values for CPT codes 92654–92663.

2. Examine the clinical appropriateness of CPT 97550, 92584, and 92651 as reference services, including whether their professional work, patient contact, clinical intensity, and resource requirements accurately represent direct SLP treatment.

3. Correct or clarify inaccurate, incomplete, or clinically unrepresentative information used or disseminated by CMS in support of these valuations, including the documented rationale for comparator selection, descriptions of professional work, and assumptions regarding clinical intensity. Where deficiencies are substantiated, reassess the affected relative values through the appropriate administrative process.

4. Evaluate internal and cross-specialty relative value and rank-order consistency, including comparison with time-based direct-care rehabilitation services such as CPT 97110.

5. Refer identified valuation deficiencies to the appropriate CMS and AMA/RUC review processes for corrective consideration.

6. Consider delaying implementation of the replacement-code framework until the identified information-quality concerns have been reviewed and appropriate corrective actions determined.

7. Provide a written response identifying the disposition of this Request for Correction, the information reviewed, any corrections undertaken, and the administrative options available before January 1, 2027.

VI. Request for Expedited Review

Because implementation is scheduled for January 1, 2027, I request expedited consideration. The purpose of this petition is not to oppose coding modernization. Rather, it is to ensure that changes affecting a substantial portion of outpatient speech-language pathology services are supported by accurate, objective, and clinically representative information.

The professional work performed should be valued according to the resources required—provider time, clinical skill, judgment, treatment intensity, and practice expense—not solely according to the disorder domain being treated.

I respectfully request acknowledgment of this formal Section 515 Request for Correction and a written response addressing the disputed information and available corrective actions.

Sincerely,

[Full Name, Professional Credentials]

[Practice or Organization, if applicable]