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SLPs had a lot of questions after our last episode on CPT 92507, so we brought back healthcare reimbursement expert Rick Gawenda to answer them.
In this Q&A episode, we talk about:
🛠️ Why CMS flagged 92507
🛠️ How the proposed 30-minute base codes would work
🛠️ Why SLP timed codes are not the same as PT/OT
🛠️ Questions about schools, Medicaid, documentation, and more
🛠️ Why CMS flagged 92507
🛠️ How the proposed 30-minute base codes would work
🛠️ Why SLP timed codes are not the same as PT/OT
🛠️ Questions about schools, Medicaid, documentation, and more
If you're an SLP allied professional trying to understand what the CPT 92507 proposal could mean for speech therapy services, reimbursement, documentation, and access to care, this episode will help you make sense of the policy debate.
The profession is watching closely, and clinician voices matter.
You can find Rick Gawenda on Instagram, TikTok, YouTube, Twitter, LinkedIn, and Facebook, or at https://gawendaseminars.com.
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Creators and Guests
Host
Jeanette Benigas, PhD/SLP
Host of Fix SLP
What is Fix SLP: Advocacy & Accountability in Speech-Language Pathology?
Fix SLP is an SLP Podcast by Dr. Jeanette Benigas about advocacy, autonomy, and reform in Speech-Language Pathology. This show exposes credentialing gatekeeping, dismantles CCC requirements, and helps SLPs advocate for change. Each episode equips SLPs with tools to reclaim their profession. Subscribe now and join the movement transforming speech-language pathology. Follow @fix.slp on Instagram and TikTok. Visit fixslp.com.
Welcome to Fix SLP, the podcast shaking up the field of speech language pathology. We're calling out the barriers that hold clinicians back, fixing broken systems that limit our care, and giving the power of our profession back to the people who live it every day. This is where fearless clinicians come together. It's time to change the field with our voices, leadership, and advocacy leading the way. So let's fix SLP.
Jeanette Benigas:Hey, everybody. Welcome back. It's Jeanette. I have Rick Gawenda again because we're not even through a full week since we launched the last episode and you guys love this man. I don't know that you're listening for me.
Jeanette Benigas:You love Rick, you love what he has to say and besides the week that Asher raised their rates, we're looking at one of the most listened to episodes we've had. So thanks for coming back, Rick. Thanks for it. Before we jump in, there's two things I want to mention. This is not a sponsored mention.
Jeanette Benigas:I want to direct everybody's attention to Stephanie over at Chomper Champs. First of all, she has been a little Fixer sleuth and has been looking at Ash's website. She did some posts about them literally changing posts since we've announced all of this. She was using the way back machine to see some things and so she's got that over there but she creates these very cute three d printed dogs and cats and then little manipulatives that you can use during therapy. I do have one.
Jeanette Benigas:I named my little dog Fil, F- I- L-, short for Filbert. Filbert the Fixer. Phil has a whole personality. I'll post his picture later this week. My kids and I are getting a cat, Construction Cat, Connie the cat is what we're going to call her, Connie for short.
Jeanette Benigas:But Stephanie is amazing and I'm going to try to announce this without crying because it's really moving to me. Stephanie has put together a Fix SLP themed kit. So she has three d printed a toolkit that says Fix SLP on it, a bunch of cute little tools, it comes with a measuring tape that's functional, she said she had to use hers the other day. Little signs, there's sensory sand if you want to turn it into a sensory kit, and then there's a construction vest and this is the part where I talk about it, I cry. Stephanie is in connection with a refugee who has some kids and is just trying to take care of her family and she has sewing skills.
Jeanette Benigas:And she's paying this woman a fair wage to make these vests and that is so meaningful to me. Just the fact that she's supporting someone like that and that Fix SLP is reaching beyond what we do every day, which is trying to improve our profession. This is someone not even linked to SLP who is working and making a fair wage and people are buying this already. She has it on presale, so when she told me this, I just started bawling. So if you're interested, Stephanie has this kit for presale.
Jeanette Benigas:I think she's planning to ship it in May and this is going to be something I think that's ongoing in her catalog at least for a while, but 20% of every sale is going to come to us and that type of sponsorship is what pays the team. So everybody knows we don't use sustaining partner donations to pay the team, but it's those little things that we can support ourselves just a little bit since we do this in real life. Please head over to Chomper Champs, check out our stuff, even if you're adult, my kids play with mine. So thank you Stephanie, we love you, we appreciate you, you're amazing. The other thing that I would like to announce and I regret that this hasn't been sooner, hopefully you all understand, You're probably all wondering what happened to Preston.
Jeanette Benigas:Preston has been on approximately half of our Fix SLP episodes as my co host. We all do this in our spare time for free. So shortly after the new year, Preston and I chatted and he has stepped back from Fix SLP unfortunately. We are still friends. There's no behind the scenes drama.
Jeanette Benigas:He is still a sustaining partner, but he has just had to move on. I said to him, I totally respect the relationship that he has built with all of you. So I would like you to tell the Fixers that you're leaving. And so he took a couple weeks to think about how he wanted to say goodbye. He has recorded us a video that he provided me literally an hour, maybe less, before I posted the first 92,507 post, so you can all understand why I haven't put that in.
Jeanette Benigas:I didn't want it to be missed and it also felt like out of place and not appropriate, but time is going on now. People are asking him, people are asking me. That video will be on our YouTube channel, and I will eventually put it into our platform. But I want to keep it out of the 92,507 stuff to help people from being confused, especially if they're new. But we have so appreciated everything that Preston has given to this platform.
Jeanette Benigas:I already miss him. I think Preston and Rick, for those of you who have followed, Preston would have had some things to say about what's going on. I miss his Prestonisms. So yeah, thank you Preston for all that you've given SLP to your state of Arkansas to Fix SLP. We love you, we will miss you.
Jeanette Benigas:Hopefully at some point in the future he'll come back as a guest, but for now, he's doing his own thing and we will miss him. He'll be missed. So Rick, thanks for letting me do all that before we jumped in. Couldn't go another week without telling people. He's in the picture still.
Jeanette Benigas:I don't even want to take him out of the picture. I told him it'll be a while. I like our new little logos for our podcast. So we'll remember him that way for a bit, but eventually I'll have to change it. All right, Rick, I asked you to come back.
Jeanette Benigas:There are so many questions. We are committed to not doing another ninety minutes. But we've got some questions. We wanted people to call in. Apparently SLPs don't like to talk.
Jeanette Benigas:We only got one call. But we did get a lot of questions. So I'm gonna play this first one. We'll get an answer for her.
Mary from Missouri:Hi. This is Mary from the state of Missouri. One of the questions that I have is it was stated in your podcast that CMS flagged ninety two thousand five hundred and seven because of a 234% increase in usage of the code from 2017 up until obviously the 2023 since the request came in in April '24. I am wondering since it's the Center for Medicare and Medicaid Services, whether it was only exclusively Medicare claims that they were reviewing or if in fact they were also seeing an increase in demand through the Medicaid system. Thanks for answering.
Rick Gawenda:That's a great question. And the answer is it's only original Medicare. So September for the previous year is called kind of Part B data summary. So being it as a Medicare Part B, this only includes original Medicare Part B data. So that increase that CMS saw is just original Medicare beneficiaries only.
Rick Gawenda:It does not include Medicare Advantage. It does not include Medicaid or managed plans.
Jeanette Benigas:All right. Our Fearless Fixers are chef's kiss. We had a woman message me who said, okay, 2017 was when this overutilization started. In 2017, the American Speech Language and Hearing Association with the C. E.
Jeanette Benigas:C, which is the Health Care Economics Committee from ASHA. I am going to link that to my website as soon as Rick and I are done with this episode, so it will be there. It is the committee that drafted this proposal that has already passed. This presentation was session number ten seventy five on 11/09/2027 in Los Angeles, California. ASHA and the HCEC reported that 97532 was deleted for 2018.
Jeanette Benigas:There was a new CPT code 97127, cognitive function intervention was going to be an untimed procedure. A couple years later, they then replaced that, correct?
Rick Gawenda:Yes. Okay. 2018, 7127 went into effect. And then it came in in 2020 then, 97129 and 97130 came in. Okay.
Rick Gawenda:They came in soon after ninety seven thousand one twenty seven did not last long.
Jeanette Benigas:Okay. It was that same year in this same presentation that the current chair of the HCEC, along with other members, presented a decision tree, began to recommend that SLPs, based on this decision tree, bill 92,507 for dementia treatment. So you and I had an entire conversation in the last episode. If you all missed it, go back and listen, where we talked about fraud and abuse. And this recommendation came straight from ASHA, the year that the overutilization started.
Jeanette Benigas:Now, correlation, causation, we don't know. Probably a link because that's the year people started doing it. They left that convention and started billing dementia treatment and other cognitive issues under language. So this Fixer messaged and said, I was in that session, didn't feel it was right. And so that's why I saved this PowerPoint and I've sent it for you to look at.
Jeanette Benigas:I mean, all these years later, she has saved it for that long. So here we are. So now we're going to hop over to Instagram. But while we do that, Rick, I put up a post this week and there have been a lot of questions even before the post. I had been planning to post this anyway.
Jeanette Benigas:Well, aren't timed codes good? I'm a medical SLP. Aren't timed codes good? Don't we want timed codes? OT and PT have time codes.
Jeanette Benigas:Now we can be like them. And my post said this is not the same. The structure of what we're facing is not the same as the timed codes for PT and OT. And so people have been asking for more examples of that. And so I thought, you're a PT, I'm an SLP.
Jeanette Benigas:Maybe we could give people an example of how they're not the same. So could you give us an example of maybe a PT doing a forty five minute session and what that might look like in terms of coding and reimbursement?
Rick Gawenda:Trevor, I even said in last podcast, you and I get, I think even PTs and OT struggle with the fifteen minute time based codes because, again, even with the pediatric child, know, as you're working on having that child and put two stupid simple examples here, as you have that child, you know, roll from supine to prone, working on kneeling, half kneeling, crawling, cruising, things like that, you know, we're gonna say that's a functional activity and we would go to that under 97,530. But, again, part of that dynamic functional activity, though, are you also working on, you know, range of motion with that child? Are you also working on balance and coordination, which would be, you know, neuromuscular education? So I even think PTs, OTs run into this kind of same problem that as we're doing an activity with a child, with an adult, with a geriatric, we're combining a bunch of things. We're combining range of motion, strength, balance, coordination, proprioception, functional activities, we then gotta try to figure out, okay, what are we really focusing on?
Rick Gawenda:What's the main intent? So that I do wanna say that I think we struggle with that. I think if you look at a typical treatment, and again, shouldn't say typical because again, it depends on are you treating pediatrics, adults, geriatrics, the condition of that. But I think a lot of what PT does in the pediatric population is gonna be functional activities. So whether they treat that child for twenty five minutes, thirty minutes, forty, forty five, we're just gonna build multiple units of say therapeutic activity.
Rick Gawenda:Now, as we get maybe into the, or just use a total knee replacement, and this could be a 57 year old total knee replacement under a commercial insurance could be a 65, 70 year old under Medicare Medicare Advantage might a typical treatment consists of, you know, say twenty minutes, strength and range of motion exercises, maybe ten minutes of manual therapy and maybe fifteen minutes of, you know, functional activities. Well, then we have to look at each code. You know, Medicare, we add that up, of course, it's forty five minutes, allows three units non Medicare. We got to look at each code by itself and how much time do we spend doing each code. And did we do that for in this example, at least one unit?
Rick Gawenda:You know, obviously with speech, with these new codes that are proposed and have been approved, you know, it's a little bit different because you've got the initial thirty minute code followed by the fifteen minutes. And I think speech has that same difficulty where you've got that patient that not only has the language comprehension speech production issues, but might they have some voice issues going on, some resonance issues going on, might they, you know, and a child stuttering going on. So you're working on all this stuff. Where are you going to put the minutes under which initial thirty minutes or under which fifteen? So it's making us kind of break it down into, quote, treating the person as a silo versus treating the whole and just having kind of an untime code that encompasses everything or a time based code that encompasses everything.
Jeanette Benigas:Right. And so what Rick just said there was basically they have all these codes that they can use and then they time them out or for Medicare, they do them in units. So a forty five minute session, they could do three different things or three of the same for forty five minutes and make make their reimbursement in that way. For us, our base is thirty minutes. So we're already behind because that's the base.
Jeanette Benigas:They're starting with a fifteen base And then we add on in fifteen minute add ons. So when we're only seeing people for thirty minutes already, how do we add in all the things that we need to add? So the discrepancy here and the argument that we've sort of put forward isn't that time codes are necessarily bad. There can be a right answer, but they have to be timed appropriately and they also have to be valued appropriately. And so this model is not the same as the model that OTs and PTs are using because they've already doubled our base time.
Jeanette Benigas:Now, Rick, some other questions that I've seen with the thirty minute base. If we want to do some add ons, do we have to meet the full thirty minutes before we can add on? Or does the midpoint rule apply to the base as well? We talked about the midpoint rule last week.
Rick Gawenda:So if we just look at the proposed code, I guess nine x zero six, I believe, should be the code for language comprehension and speech sound production combined the initial thirty minutes. To be able to build one unit of that base code, you have to do interventions that meet that definition for at least sixteen minutes. Now to build the add on code for that, which right now is nine zero x zero seven, you have to have to technically do thirty eight minutes. So you have to do the whole thirty minutes to cover the base code, and then you have to do eight minutes into the each additional fifteen. You have you have to pass midpoint.
Jeanette Benigas:Right.
Rick Gawenda:What could possibly happen is could you have the base code for speech sound language comprehension expression? And I see you work on that for sixteen minutes, you can build a base code. Then if this person also has fluency issues, stuttering, cluttering, and you worked on that for sixteen to twenty minutes, you could build that base code as well. So it's possible you could build two base codes in the same treatment session for a total of thirty two minutes. You know, you had at least sixteen minutes in that example of speech, sound language comprehension, and then sixteen minutes doing fluency.
Rick Gawenda:Now, what we don't know, of course, and run the assumption these codes will come out. So let's go on assumption they come out. What could be the NCCI edits? What will Medicare and Medicaid allow to be reimbursed on the same day? And they may allow what I just said to be done the same day, but might you have some payers, of course, not allow it?
Rick Gawenda:Because I'm sure, Jeanette's, many of your SLPs know that a lot of programs don't pay for feeding swallowing at all, or they don't pay for feeding swallowing the same day you work on speech language issues.
Jeanette Benigas:Doctor. So we don't know. I have seen that question too. Will I be able to add dysphagia on to what I'm doing? We don't know yet.
Jeanette Benigas:And if this proposal passes, we might not ever know because it would send it back to the table. But if the effort of the new application does not pass, then that will be out this summer. And that's when we will know.
Rick Gawenda:Doctor. Yeah, I mean, opinion, if the proposal that's been put forth, you know, does not pass and the codes move forward as is, do I think Medicare and other payers that are paying for 92,526 on the same day as you know, right now, 92,507? I think that will you I do. I don't think that's going to really change anything in the feeding swallowing issue. I don't think that's going to be the issue.
Rick Gawenda:It's just with these new codes, what would they allow to be done on the same day?
Jeanette Benigas:Yeah. Yeah. Those have been really good questions. So I'm glad people have been asking those just for clarification. I have my own question.
Jeanette Benigas:So, we're doing a thirty minute base, let's say, for expressive receptive language. But I also want to treat fluency. Can I do the base thirty minutes and then add the fluency add on? No. Okay.
Jeanette Benigas:I didn't think so.
Rick Gawenda:No. You cannot build the add on without building the base for that same CPT code first.
Jeanette Benigas:So there's no mix and match. That will be a very good post.
Rick Gawenda:Well, kind of, that example of what you just said of doing speech, sound language, comprehension expression, you know, that's going make you do it for at least sixteen minutes. You know, I'll you do the add on of another code. You don't have do it for eight, but you can't because you gotta do the base code first. So really, to build two different base codes on the same date of service, you're looking at a minimum of thirty two minutes of treating that patient. Sixteen minutes focused on one base code, sixteen minutes focused on another.
Jeanette Benigas:And then if we want to expand this a little more OT and PT, do they have that rule in their model or those are just units, treat whatever you want, mix and match, match them up. Right?
Rick Gawenda:Well, for the most part, PT and OT can, you know, mix and match TheraX versus neuro versus manual therapy versus therapeutic activity versus, you know, some other codes. For the most part, we can do that without needing modifier 59. There are times we have to use modifier 59. And, again, there are some pair of codes Medicare and Medicaid would not pay for the same day as PT and OT. So we don't have complete free rein.
Rick Gawenda:Yeah. A lot of the thing a lot of our major codes that we bill a lot of can be done the same day to service and paid without requiring any special modifier 59.
Jeanette Benigas:Yeah, so that's another example how this is not the same structure. We have some folks out there that have pretty large followings that have been posting, while everybody's freaking out about 92,507, I'm excited. This in our opinion, this isn't really something to get excited about. Remember, Rick and I have seen this stuff we've been following along. We're waving the flag.
Jeanette Benigas:This is probably going to be a problem. And so we're giving those reasons why this isn't PT and OT. This isn't the same. And everybody can go visit that post if you'd like. So let's jump to our next question.
Jeanette Benigas:This one's from Facebook. This is Jessica. Under the proposed codes, would we be able to bill services for a patient that has an expressive or receptive only diagnosis?
Rick Gawenda:Yeah, sure. My opinion, obviously, we don't again, we're under assumption that these codes move forward. Okay. And if they do move forward, there'll be further guidance that will come out. But, you know, right now, we know it's gonna be a base code for fluency, a base code for speech sound, a base code for, voice and resonance, a base code for speech sound production and language comprehension expression, and then a base code just for language comprehension and expression.
Rick Gawenda:So if that patient, you know, has normal speech sound production, maybe you screened, don't need to go there at all. It's fine. And you have to focus on language comprehension and expression. There is a base code for that, as well as the additional fifteen minutes for that.
Jeanette Benigas:Here's another question that has come in. It's one I've gotten a couple of times from school SLPs because we have said this is going to touch every person somehow. Go look at our content. The IEP's in our district are for two times a week at fifteen minutes. Are they going to be able to do that?
Rick Gawenda:So again, I know I've said I follow a lot on social media and I've seen posts from SLPs and others saying, well, schools don't bill insurances, they don't bill Medicaid. Actually, of them a lot of them do, you know, program and they are funded by Medicaid. The new codes go through as they've been approved. You would actually need to do sixteen minutes to go a base. You need two times a week for sixteen minutes technically to go to the base codes.
Rick Gawenda:Yes. If you've been, Medicaid is going be covered in a school system or a commercial pay.
Jeanette Benigas:We did hear from a school that's bringing in $1,600,000 a year just from speech services. So that's a big deal. Now, Rick, what I'm wondering is we're rating an IEP for twice a week at sixteen minutes. Is that going to be a flag for an audit since the base code was meant to be thirty? So if we see a school billing Medicaid every time twice a week for sixteen minutes, does that open them up to some trouble down the road?
Jeanette Benigas:Do we think?
Rick Gawenda:That's a good question. I actually just published an article on my website where I answer that question about if I if I do a code for less time consistently, is there a risk for it? And I think the risk is now, let's say, Medicaid audit stat score system. And so they request 50 speech therapy medical records and they look at each one and the SLP documents he or she treated that child for only sixteen, seventeen, eighteen minutes. Yet, we know the value of these new codes coming out.
Rick Gawenda:It's really five minutes pre service time. Some of them are thirty three minutes face to face, five minutes post in there somewhere depending which code. So you're looking at about forty three minutes, you know, thirty three minutes one on one with some pre and post time. So my experience has been when an insurer audits that and they can tell that for every child in this example, that SLP that school system treats is only seen for sixteen to seventeen minutes. But we're basing our payment on thirty, thirty three, thirty four minutes.
Rick Gawenda:I'm not saying you're quote in trouble, but could it make the payer down the road leave that CPT code? So if they say everybody's only doing sixteen, seventeen, eighteen minutes on on one time, do they change that intra service media Could be the could be a risk. Yeah. And I also understand their argument. Obviously, I know that a lot of pediatric therapists are trying to prove the point that, you know, kids can't handle twenty five, thirty, thirty two, thirty three minutes.
Rick Gawenda:And I understand that. But then you also have to understand what the insurance may do if if it's because obviously they're valuing it on that page, even that amount of therapy.
Jeanette Benigas:These are some points to address whether you are in support of the new code structure that's been passed or you're not a fan of what's happened. These are the types of things that you should be talking about in your open comment, not the money. We all know money is probably going to be a problem, but as I've been putting out now in a lot of posts, this is not that part of the process. That comes after a code structure is approved. So structure first, then REC evaluation conversation.
Jeanette Benigas:So these are the kinds of things that you could be saying that this is how these are the types of kids we service. This is how we found to best service them. What has been put forward is not the right structure for our area that we're working in the field. That is a better conversation in your comment.
Rick Gawenda:And again, my opinion, I'll just reiterate what you and I spoke on a couple of weeks ago or last week, whenever it was, you know, whether you do pediatrics, adults, geriatrics, I think a couple of key things for all three of those areas. The word communication is missing in all five of the code.
Jeanette Benigas:The
Rick Gawenda:words auditory processing disorder is missing in all five of the codes. So I think that's one point. A second point, I think, more so on the pediatric side, is that point of the child. Many children can't handle twenty five, thirty minutes because of the attention span, tantrum, eight, whatever it may be.
Jeanette Benigas:Right.
Rick Gawenda:Nothing you have to do that. The other thing for all three peds, adults, geriatrics, is we don't treat in a silo.
Jeanette Benigas:Mhmm.
Rick Gawenda:As we're working with that patient, we may be working on voice, speech sound, language comprehension, and expression all at the same time. Would I put these minutes and which is the best one to use? That could make you choose the code that pays the most money, even though documentation shows you're actually doing something else that actually technically pays less. So I think those are some of the arguments to make when the agenda comes out this Friday, March 6.
Jeanette Benigas:I don't know that this is one that we could answer. This is asked on Instagram. A version of this has been asked a couple of times in a couple of different places. And it's why is the new code structure that has been approved? Why wasn't the OT and PT model proposed?
Jeanette Benigas:Why wasn't the counseling model proposed? Why weren't these models that are already in use used? Why is ours different? Do we know that answer?
Rick Gawenda:I mean, I do not know the answer. Gonna assume ASHA and whoever was involved in initial application process, maybe felt that the typical treatments window, so to speak, is at thirty minute. I do know in 2024, when we had those new caregiver training services, CPT codes come out, 97550 and 97551, That's in that initial thirty minutes. So 97550 is that initial thirty minutes of caregiver training done without the patient present, and then 97551 was each additional fifteen minutes. So I can't answer why I was involved in that process.
Rick Gawenda:Right. Again, I said it last time. If if SRP is going to go to time based, either a time based code or time based codes, do I think it should be in fifteen minute increments? I do. I just think that makes more sense, in my opinion.
Rick Gawenda:I also think, you know, people are worried about the reimbursement, and I get that, and unfortunately, we just don't know what the reimbursement would be because the practice expense are we knew we cannot calculate that until CMS gives us that number. But I do know that the work RVU has gone up significantly because the cost of the speech language pathologist has gone up. Also, you look at the practice expense piece of it, the equipment now the SLPs are using the technology that they're using during the treatment. So it would be interesting if we could truly see what the PE overuse would be for these codes and how close it actually comes to the reimbursement for 92,507. It's an untime code.
Jeanette Benigas:Yeah.
Rick Gawenda:Part of me hopes we don't see it in July.
Jeanette Benigas:Me too.
Rick Gawenda:If we don't see it in July, it means what's happened in Boston was successful.
Jeanette Benigas:And that is unfortunate. So this is airing on the fifth. The open comment window opens on the sixth. I'm going to move. Well, I can't I don't think I can make a comment because I put in the application.
Jeanette Benigas:But if if I were making a comment, I would just be operating under the assumption that we're going to make less money because Medicare does this to reduce what they pay. I also want to say I'm going to put this in there, too. I personally have been in contact with nearly half of the state associations in this country who are either interested in learning more or they already know enough and they want to know how they can support the new application. There have been some very productive conversations. I do want to say it's important for you to make your own decisions and look at everything we've been putting out.
Jeanette Benigas:Everything that I put out has source documentation. It's all coming from the AMA website or I'm researching how the new codes will impact different areas of the field. So I'm doing a lot of research to put this stuff out. Remember that right now, the only person who has seen what has gone in is literally me. So when you're getting these states and I'm seeing it from the states who haven't talked to us, and that's fine.
Jeanette Benigas:They have feelings about Fix SLP or Jeanette Benigas whatever. They're saying we're doing research. They're missing half the story because they don't know what our little team has put forward. So just keep that in mind. It's okay to read what they're telling you.
Jeanette Benigas:It's okay to take that as part of your own research because you should do your own research. But remember, you're only getting half the story if you're looking at just their stuff. And I have a feeling that the people who need to hear this aren't the ones listening, but just keep that in mind. We've tried to get some meetings with a couple of these states to help them gain more information and it's just not happening and that is what it is. But we're also seeing these states are giving out the ASHA talking points.
Jeanette Benigas:So ASHA has recognized that a new application has been put forward. That's on their website. I have it linked up at fixslp.com under the CPT 92507 code. But in the talking points that states are giving you, they're not even talking about the new application at all. They're basically telling you what's done is done, and now we move forward and we will find out more when Medicare publishes the rates this summer.
Jeanette Benigas:And we don't want you to miss that what's done is not done. What's done can be undone. And that is the point of what the private practice owners that I'm working with and a large membership organization, a nationwide membership organization, what we have all done to sort of help undo this. What's done is not done. We can stop it.
Jeanette Benigas:So just remember that that these talking points are only half the story. We can do a lot, which is literally stop this and then work to get it back at the table for some better revisions. Because I think if we don't revise it, it'll be revised for us. So we want to have our voices heard as part of that process. And so that's really two: important to remember that some of the talking points out there don't include the whole story.
Rick Gawenda:And also, I know Jeanette has put this out and Fix SLP too. You can sign up to attend virtually that opened up the registration opened up. So hopefully you will sign up to listen virtually April 30, May 1, May 2. And as Jeanette said, you will see what was put forth come March 6 when she's get the agenda and then you can, you know, become an interested party and sign the confidentiality and then you'll get to download that packet.
Jeanette Benigas:Yeah, there are some people who did make it that they made it. It's closed now to view in person. Rick said last week, it fills up fast, it's filled. So there are a couple of people coming in person. And what I will do after the open comment period starts is I discovered in putting out my newsletter last week that I have the ability for people to sign up for text messages.
Jeanette Benigas:And what I will do if you have signed up to watch virtually, there will be an agenda that's put out. So you'll know generally the day and time that I'll be talking with a colleague. But that is flexible because it's my understanding that they give every topic as much time as it needs. The last day is actually an overflow day in case they run over. So I will give live updates via text message because you're all at work.
Jeanette Benigas:Nobody is sitting at home watching this meeting all day. Nobody wants that. So I will put that out there. Be on the lookout for it. I will also put the link when it posts to the fixslp.com under the 92507 tab.
Jeanette Benigas:Everything we're collecting, I'm pushing there. So you can go there first tab under the menu. It'll be there if you want to sign up for those live updates. That way you don't have to watch. You just watch your phone.
Jeanette Benigas:Were there any I really wanted to stay committed to less than an hour, Rick. Were there any other questions that you've seen that we haven't gone over yet that you think are important to address?
Rick Gawenda:I think you and I are on the same line just trying to keep people calm about the money. You know, I agree with what you said. It's not a done deal yet. And, you know, obviously, I know there's some groups out there saying it's done, it's coming, it's the end of the world. I'm going to lay off speech language pathologists, our kids want people to be taken care of adults, etcetera.
Rick Gawenda:It's not done yet. You know, I I don't know if I can. I'm going to say it. Do I think we have a very good chance of, I guess, for lack of a better word, winning this on April 30 to May 2? I do.
Rick Gawenda:I think we have a very good chance. I really think the SRP community and others that are interested in this have really come together. I think you've got a great team behind you moving forward with this. It's just I do agree we gotta stay focused not on the money, but just why these codes do not work. And I think if we do that and we just present it very, very well, I think you're going to be successful come April 30, May 1.
Jeanette Benigas:Fingers crossed. I like to win. So I like calling it winning. Okay. Listen, if I'm gonna dress up, nobody could see this.
Jeanette Benigas:I have on a nice or top, but I've got track pants on. Okay. I don't wanna dress up. I'm a med SLP. I wear scrubs.
Jeanette Benigas:If I'm gonna dress up, it better be for a really darn good reason.
Rick Gawenda:That's definitely for that one.
Jeanette Benigas:Some other questions we've been getting. How can we get families involved? We made the executive decision to not put out any family informational material until after the comment period opens. Comment period opens if you're listening to this the day that it drops tomorrow, March 6, it goes through March 31. Given the panic that the SLP community went into when all of this started happening, I thought it would be best if we waited to tell families because people, especially parents, get emotional about their kids.
Jeanette Benigas:And if they're afraid that they're going to lose services, that's a problem. So I wanted to make sure that there was something very actionable that could be done from the moment they find out. And this whole process is kind of complicated. We're doing a Q and A episode because people are still confused. So I thought, you know, we all service different levels of families and individuals that may or may not be able to handle all of this information and write an open comment that would make sense.
Jeanette Benigas:So I thought, you know, it would be better if we just waited. We let all of you go in, do your open comment, read the packet, the application that was submitted and decide for yourself. You know what, the community that I serve could handle this. I'm going to put it all out there. Or I don't think anybody I serve can handle this.
Jeanette Benigas:I'm not even going to talk about it with them. Or I've got these 10 powerhouse parents that come to my clinic and I'm going to reach out to them individually to ask them to support this. So I thought it was best to give you all that autonomy to figure out what you wanted to do and then have some knowledge about how to push people forward. Rick and I talked last week that if we both signed the confidentiality agreement, we can talk amongst one another. So if you've already signed it and a family is interested in supporting and they're going to sign it, then you can kind of help them write or if it's something if you work with adults and you want to do this as part of a therapy session, can go in there, help them sign that confidentiality agreement and help them write their letter or their open comment.
Jeanette Benigas:That will be coming in the next few days. We're getting that prepared behind the scenes now. All of that will be available at fixslp.com because that's the only place I have to land things. Go there. There's a tab.
Jeanette Benigas:You can download it. Or probably also, I've been utilizing a lot of use the word whatever. So in this case, it might be use the word resources for the link to download and then it'll just give you the link to download the resources from social media. So that's something that's coming. You can be talking to your friends, friends, doctors, referral sources, all of those professional colleagues.
Jeanette Benigas:You can be telling them now. Well, and it starts tomorrow if you're live. So, yes, get that. They can send letters. The other thing is, if you are working for a large company, the AMA told us, literally told us, your coalition's not big enough.
Jeanette Benigas:You need to get more people supporting this, some larger organizations. So if you work for a big school district or a big hospital system or a big whatever, talk to your employers about putting in a letter of support. Take some of these materials that we've been putting Let them know how this is going to impact them economically because that's really what our employers typically care about. Make sure they understand you can't talk about that really in the comment, but try to get somebody from your organization to submit a comment from the organization. That will go a long way.
Jeanette Benigas:The AMA told us, literally told us, we're not allowed to lobby, but we need to get support. I don't know how those go hand in hand, but they told us we needed to do that. So I think that's it, right? This thing goes live tomorrow. If people are listening live, if you're jumping in after the day we we drop the episode, it's already there.
Jeanette Benigas:You have until March 31. We cannot assume that they are going to give an extension. So don't wait. I always used to tell my students plan for tech issues. Don't wait until two minutes before the portal closes.
Jeanette Benigas:Plan ahead. So you get your assignment in on time.
Rick Gawenda:Yeah. And numbers do matter. You know, even if they we all say the same thing, if they can get five, six thousand of the same thing, that means something. Do they have to look at them all? They have to read them all versus only getting 50 of of the same thing.
Rick Gawenda:So it's okay if we all say the same thing, but we have to submit the comments. This is your chance. This is your voice. So, again, I know Jeanette likes to win. I like to win and all that.
Rick Gawenda:We don't always win. But even I say we're not winning this, Okay? But there are times where I don't win. But if I did everything I could and did not win, I feel okay because I gave it all. Mhmm.
Rick Gawenda:There's nothing worse than somebody complaining about not winning, and I ask someone, did you do this? No. Right. When they're complaining, you didn't you didn't help. So give it all we got.
Rick Gawenda:And I think we had a great chance that focus on what's missing out of the codes. Don't treat in silos as some examples.
Jeanette Benigas:You know, who else likes to win is my husband. So he will also be putting in a very intelligently written comment that he may or may not get help with because it's you know, we take a pay cut. Now our household expenses have to be managed better. So this impacts a lot of people, right? So, you know, my mom, my mom might be making a comment, get your people together, guys, get your people together, because the AMA says anybody can be an interested party.
Jeanette Benigas:So that reminds me, I have seen quite a few people ask for a template. I can't put that out. I think that falls under lobbying for support. I've been telling people, I think your comment will go further if you tell your story on how this is going to impact the people that you're serving. Is it beneficial if somebody out there wants to put out templates or should they stick to their own unique?
Jeanette Benigas:Narrative.
Rick Gawenda:Yeah, I mean, I think both are good. Okay, Okay, now obviously, how in your story is the best. And again, your story, not financial, your story about the types of patients you see that they have a wide, which in a wide range of issues that some of the people we see, they can only tolerate fifteen, sixteen, eighteen minutes of therapy. It's got to be the short bursts, you know, things like that. With that said, do templates work?
Rick Gawenda:Absolutely. Because if you look at APTA, AOTA, I'm not sure if ASHA does it. You know, when CMS releases releases a proposal in July, we get to comment on that. And, you know, APTA provides a template that people can use and just sign off on it. But they also provide that same template where you can fine tune it, you know, add things specific to yourself.
Rick Gawenda:So again, number one, numbers do matter. Okay, but obviously there's nothing better than your story and the types of patients you treat and why this won't work for you. And again, if you treat kids with auditory processing disorder, where is this going to fall? Could this open up without those three words in a code? Could this impact patients receiving therapy because Medicaid may deny services because those three words don't show up in any code?
Rick Gawenda:The word communication does not show up in any code. Which code am I supposed to bill? Does that, you know, put me at risk from an owner perspective in terms of maybe fraud, abuse, number one? So that's not money that's impacting your life, that's impacting your business and all that. So I think telling those kind of stories.
Jeanette Benigas:Yeah, that's great, Rick. It's a great place to end. We'll stop right there. On the sixth, I know the general time that the public comment will be opening. They did let me know what time that might be because it's not published.
Jeanette Benigas:I can't say it out loud, but I will start watching the website as soon as it's live. I will be posting and sending out an email. The email will have all of the cumulative tips that we've been getting for you to write an effective letter either for or against because I can't convince you either way. But the tips on what to say and how to make this effective will be in the email. The post will say, comment the word go for the link to the tips, and then you could just say the word and I'll send you the links instantly.
Jeanette Benigas:Go to the website, they'll be there. There'll be a lot of places to get these resources. This isn't something you're probably going to write in five minutes. You probably want to set some time. I think the packet is 41 or 42 pages long, so you're going to need some time to really read and think.
Jeanette Benigas:And I will say this, because this is not done often, there was not a form for us to use. So, the AMA worked very closely with us on how to submit our materials. You want to pay attention, whether you like it or you hate it, you want to pay attention to the addendum. The addendum has the rationale and the purpose for the whole application. I may or may not have had a part in that addendum.
Jeanette Benigas:It's very well done, Rick. There's superscripts with 30 articles. It's unbiased. Okay. That's what you want to read the whole thing, but the addendum has the meat and potatoes regarding what you need to think about and talk about.
Jeanette Benigas:So look at that addendum. Don't skip the attachments because there weren't boxes on the application for us to fill out. So Rick, thank you for coming back. The people love you. Hopefully they love this one as much.
Jeanette Benigas:And maybe in the May, we'll have you back to talk about what happens next. Good or bad. I don't know. Win or lose. So thanks, Rick.
Jeanette Benigas:I appreciate it. Are you going to be live in person or are you going to be watching virtually in May for the meeting?
Rick Gawenda:I will be watching virtually because my youngest daughter graduates college on May 1. Aw. I love that. I love your seat. I love the SLPs, but I, you know, love the daughter a little bit more.
Rick Gawenda:So
Jeanette Benigas:Family first. Family first.
Rick Gawenda:I'm hoping, you know, that SOP goes on that Thursday, so we'll find out.
Jeanette Benigas:Well, you know what? Sign up. Sign up for the text messages so you don't have to watch.
Rick Gawenda:Well, I will
Jeanette Benigas:personally text you.
Rick Gawenda:All right.
Jeanette Benigas:Get in tomorrow. Or if you're listening late, go to that open comment period, download the packet, and get going. We'll see you next week. Thanks for fixing it.
Rick Gawenda:Thanks, Janette.
Jeanette Benigas:Thanks for listening to the Fix SLP podcast, the podcast shaking up the field of speech language pathology. Don't forget to check out our social media or fixslp.com for our latest promo codes for continuing education, therapy materials, merch, and more. Supporting our sponsors also supports our Fix SLP team. Don't just listen. Be a part of the change.
Jeanette Benigas:Share this episode and our social media content, and let's keep fixing the field one fight at a time.