Request for OIRA Review — Coalition To Protect Patient Access To Speech-Language Pathology Services

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Help protect patient access to speech-language pathology services. Request federal review of the CPT 92507 replacement codes before implementation.

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Dear OIRA Administrator and Regulatory Review Staff:

I am writing to request immediate review of significant structural and methodological concerns regarding the deletion of CPT 92507 and implementation of ten replacement speech-language pathology (SLP) treatment codes, CPT 92654–92663, scheduled for January 1, 2027, under the CY 2027 Medicare Physician Fee Schedule.

As a licensed SLP, I respectfully request that OIRA examine concerns detailed in the CMS public comment posted by a practicing speech-language pathologist who co-authored a book in healthcare auditing: Mismanaged Money In American Healthcare: Problems and Solutions, and seek clarification and corrective action from CMS before completing its review of the final rule.

1. Fatal Actuarial Flaw in CMS’ Budget Neutrality Modeling.

CMS has publicly justified its budget neutrality and utilization projections on the historical baseline assertion that CPT 92507 was billed as a standalone service 75% of the time. This baseline is a complete mathematical fiction that ignores the agency's own compliance infrastructure. CPT 92507 is an untimed bundled code subject to once daily reporting restrictions and cannot be billed with specific unbundled physician medicine, cognitive, sensory or overlapping group or evaluation codes.

2. Inappropriate Timed and Untimed Reference Codes Used In Valuation

The proposed valuations rely, in part, on comparison services fundamentally different from direct, one-on-one speech-language pathology treatment, including:

CPT 97550: A timed caregiver-training procedure performed without the patient present.

CPT 92584: An untimed electrocochleography diagnostic procedure.

CPT 92651: An untimed auditory evoked potential diagnostic procedure.

Two of these reference procedures are untimed diagnostic services, while the third involves caregiver instruction without the patient present. None adequately represents the continuous therapeutic engagement, clinical decision-making, and professional intervention involved in direct speech-language treatment.

Using clinically dissimilar reference procedures to establish relative values for timed, direct-contact treatment raises serious questions about the validity and clinical representativeness of the resulting valuations.

3. Retention of CPT 92508 Exposes A Fundamental Inconsistency in the Proposed Code Family

Of particular concern is the retention of CPT 92508, an untimed, comprehensive group speech-language pathology treatment code encompassing speech, language, voice, communication, and auditory processing disorders.

CPT 92508 remains defined by the procedure performed — group treatment of two or more individuals — rather than by the patient’s disorder domain.

In contrast, CPT 92507, the corresponding individual treatment code, is being deleted and replaced with ten timed, disorder-specific codes carrying different relative values.

Group treatment across multiple communication disorder domains remains reportable under one comprehensive, untimed procedural code, while individual treatment must be divided into disorder-specific categories with unequal reimbursement values.

Although individual and group treatment are distinct services, the continued recognition of a comprehensive group-treatment code raises a critical question: Why is disorder-specific fragmentation considered necessary for individual treatment but not for group treatment?

The retention of CPT 92508 demonstrates that a procedure-based code encompassing multiple communication disorders remains viable within the same treatment code family. This inconsistency calls into question the rationale and internal coherence of the proposed restructuring.

4. Unequal Valuation Of Comparable Professional Services and Misclassification of Rehabilitation

The replacement codes assign different reimbursement values to comparable durations of direct provider care based on disorder classification rather than the professional procedure performed.

Thirty minutes of treatment for fluency or voice disorders does not inherently require less professional skill, clinical judgment, or intensity than thirty minutes of speech sound production treatment.

Similarly, the proposed speech sound production and language treatment category describes intervention addressing two disorder domains within the same 30-minute period. The presence of two disorder domains does not, by itself, establish greater clinical complexity, professional effort, or resource consumption than treatment addressing a single domain rather implies more than one disorder can be treated during the time framework. The disorders are not treated simultaneous in the minute.

The number or classification of disorders treated is not a reliable measure of the professional resources required to deliver rehabilitation.

Furthermore, the proposed framework risks treating communication rehabilitation as a series of discrete, transactional services with clearly defined clinical endpoints corresponding to billing increments.

Although timed codes appropriately measure the duration of professional services, they do not establish the boundaries of the underlying therapeutic process.

Rehabilitation of a communication disorder is longitudinal, individualized, and cumulative. A functional communication deficit is not ordinarily resolved within a single 30-minute treatment block. Each encounter represents one component of an ongoing therapeutic process requiring continuous assessment, adaptation, skilled intervention, and clinical judgment.

The same professional qualifications, clinical resources, and therapeutic responsibilities apply throughout that process, regardless of whether treatment addresses speech, language, fluency, voice, or multiple communication domains during the encounter.

By assigning different relative values according to disorder domain rather than demonstrable differences in provider work and practice expense, the proposed methodology risks creating artificial distinctions between clinically comparable services.

These disparities raise serious questions about internal relative value consistency under the Resource-Based Relative Value Scale and Section 1848 of the Social Security Act, 42 U.S.C. Section 1395w-4.

The central issue is not the use of timed billing increments. It is the use of disorder classification as a proxy for professional resource consumption without sufficient evidence that the resulting valuation differences reflect actual clinical work.

5. Economic Consequences and Patient Access Risks

CPT 92507 has historically accounted for approximately 95% of outpatient speech-language pathology treatment claims . Its deletion represents a substantial restructuring of reimbursement for the profession.

The historical administration and reimbursement of CPT 92507 have also been examined in the published healthcare reference work Mismanaged Money in American Healthcare: Problems and Solutions (McFarland & Company). Authored by myself, the book examines CPT 92507 billing and payment practices within the Texas Medicaid program. According to WorldCat, the work has been published in three editions and is held by 83 libraries, including collections at Stanford University, Vanderbilt University, and the University of Texas. This specialized clinical and reimbursement research provides relevant historical context for evaluating the economic consequences of deleting CPT 92507 and implementing the proposed replacement framework.

Analyses of the proposed valuations identify potential reimbursement reductions ranging from approximately 4.6% to 34.41%, depending on the treatment domain.

These reductions could threaten independent practice sustainability, discourage provision of lower-reimbursed services, and reduce access to medically necessary care.

I am concerned that the economic consequences for small healthcare businesses and vulnerable patients have not been adequately evaluated.

6. Implementation Readiness

The January 1, 2027 implementation date introduces significant operational risks as CPT 92507, which accounts for 95% of all SLP service claims, will also be deleted January 1, 2027.

Medicare, Medicaid, commercial insurers, electronic health record vendors, and billing systems must accommodate an extensive restructuring of outpatient speech-language pathology coding.

Insufficient transition time could result in claim denials, reimbursement interruptions, increased administrative costs, and disruptions in patient care.

7. Request for OIRA Intervention

I respectfully request that OIRA, within its regulatory review authority:

1. Examine the clinical appropriateness of the timed and untimed reference services used to establish the proposed valuations.

2. Investigate the methodological inconsistency created by retaining the comprehensive, untimed CPT 92508 group-treatment code while eliminating the corresponding comprehensive individual-treatment code, CPT 92507.

3. Request that CMS substantiate the differences in work RVUs and practice expense values assigned to comparable durations of direct treatment.

4. Request that CMS explain how the disorder-domain valuation methodology accounts for longitudinal rehabilitation, including why treatment involving multiple communication domains within the same 30-minute period warrants a different valuation absent demonstrated differences in professional work or practice expense.

5. Evaluate whether the regulatory impact analysis adequately addresses small-practice sustainability and beneficiary access to care.

6. Assess Medicare, Medicaid, and commercial payer readiness for implementation.

7. Request that CMS request delaying implementation until the valuation inconsistencies and operational risks have been adequately addressed.

8. Request that if AMA infrastructure constraints force the deletion of CPT 92507, CMS must bypass the flawed RUC reference selections and legally crosswalk the new timed codes/domains to this historical, validation valuation of CPT 92507.

9. Request that CMS isolate State Medicaid multi-unit data anomalies and private equity tracking from Medicaid Part B utilization screens.

10. Formally request an operational postponement of the deletion of CPT 92507 by the AMA.

CONCLUSION

I support accurate coding and appropriate recognition of professional treatment time. However, reimbursement should reflect the actual resources required to furnish care, including provider time, professional skill, clinical judgment, effort, and practice expense — not simply the patient’s diagnostic classification.

The retention of CPT 92508 while deleting CPT 92507 exposes a significant inconsistency in the proposed methodology. A comprehensive, procedure-based treatment code remains acceptable for group intervention, yet the corresponding individual service is fragmented into disorder-specific categories with substantially different reimbursement values.

Combined with reliance on clinically dissimilar reference procedures and a valuation structure that does not adequately reflect the longitudinal nature of communication rehabilitation, these inconsistencies warrant independent regulatory scrutiny.

A billing interval measures time. A disorder domain describes the condition being treated. Neither, independently, establishes the intensity or value of the professional service.

I respectfully urge OIRA to seek clarification and corrective consideration from CMS before completing its review of the CY 2027 Medicare Physician Fee Schedule.

Thank you for your consideration of this urgent matter.

Respectfully submitted,

Name and credentials

Because the CMS open comment period officially closed on September 14, 2026, CMS is legally permitted to keep moving forward. They are currently drafting the Calendar Year (CY) 2027 Medicare Physician Fee Schedule (MPFS) Final Rule, which is slated for publication in November 2026. Under administrative law, they can fold in our 515 arguments, which are extremely strong, into the final rule's preamble rather than halting their timeline.

To try and ensure a delay or alteration before that November publication date, we can bypass CMS and target the executive and legislative oversight bodies currently reviewing the rule.

Summary of Steps

Submit your formal Section 515 Information Correction Request directly from this site.
Submit the OIRA meeting request to get an emergency audience with OMB. Office of Information and Regulatory Affairs (OIRA) operates within the Office of Management and Budget (OMB).
Send the Congressional Brief to your representatives on the House Ways & Means or Senate Finance committees to apply legislative pressure. A summary of the email is included in this campaign and will be sent to your US Representative and US Senators based upon your address and zip code.

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Contact OIRA Today

SLP Patient Advocacy

Reimbursement Rates Should Never Be Tied to Patient Diagnosis or Disorder

slppatientadvocacy@gmail.com