It’s Time to SPEAK: Part 3 - How to Write a CMS Comment That Matters

The data is collected. Now it’s time to make sure CMS hears from SLPs.

In Part 3 of It’s Time to SPEAK, Jeanette Benigas, PhD/SLP, and Emily Watkins, MCD/SLP, walk through the new SPEAK Project CMS Comment Builder and explain exactly what clinicians and practice owners should tell CMS about reimbursement, workload, patient access, and the real-world consequences of the proposed 2027 Medicare payment changes.

If you submitted economic data to the SPEAK Project, wait until September 10 to build your comment so you can incorporate the aggregated findings. Everyone else can start now.

And don’t wait until the last minute.

Visit SPEAKProject.net to build your CMS comment, mobilize the Friends of SLPs in your life, and help fund the legal and lobbying team that will carry this work forward.

Learn more and support the project at SPEAKPROJECT.NET.

Get caught up wherever you stream podcasts!
#110: CPT 92507 Is Being Deleted? What Every SLP Must Know About the New Speech Therapy Codes
#111: CPT 92507 Q&A for SLPs: Your Questions Answered
#113: CPT 92507 Option B: This Is Our Week to Advocate
#115: CMS's NEW Pediatric G Code Explained: What Every SLP Needs to Know
#116: What the New Speech Therapy Codes Mean for Adult SLPs
#117: The End of CPT 92507: Is Your SLP Documentation Ready?

#118: It’s Time to SPEAK: Part 1 - Building the Data to Fight for SLP Reimbursement

#119: It’s Time to SPEAK Part 2 - Mobilizing Families for SLP Advocacy

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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 Jeanette Benigas, PhD, 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.

Jeanette Benigas: 00:04

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: 00:31

Hey, everybody. Welcome back to the fix SLP podcast. I imagine this might be the first time some of you have joined us, but this is a highly anticipated episode, so I'd like to reintroduce myself. I'm Jeanette Benigas, the owner of PhDSLP. This is episode number 120 or 121, so we've been around for a while.

Jeanette Benigas: 00:53

If it's the first time you've found us, thanks for being here. I am running the Speech Pathology Education Advocacy and Knowledge Coalition with my colleague and friend, Emily Watkins. We'll let her introduce herself in a moment. But part of this process has been collecting data from the profession's business owners that we can use to advocate for higher rates with CMS because that doesn't exist for our field. And we don't wait for change, we make it around here.

Jeanette Benigas: 01:23

So, we had to do this ourselves. Our national organization should have been doing something like this, but they weren't. So here we are. Over the last two weeks, we have successfully raised $50,000 to pay the firm that is running all of the data and aggregating the data that we will have to give to CMS at the end of this comment period, which ends September 14. The next part of this is phase two.

Jeanette Benigas: 01:51

In phase two, we need to pay a lawyer and some lobbyists to get our data into the right hands and to get the meetings that we need and to get into the ears of the people on Capitol Hill. That will include comments from what we're calling friends of SLPs. Those can be patients, former patients, parents, loved ones, power of attorneys, neighbors, friends, your mom and dad, whoever, people who know about SLP can send a letter to key players on Capitol Hill. And our lobbyist, once we hire them, we're gonna have a team of four lobbyists and lawyers, will get these letters into the hands of the right people. It is very quick, very easy.

Jeanette Benigas: 02:41

Emily has spent hours and hours and hours coding this stuff, getting it together. All you have to do is pass out a link. They can voice memo answers or type them into a Jot form, and we do the rest. A unique letter will be created on their behalf. When they submit, they check a box that gives us permission to submit that letter, and it's done.

Jeanette Benigas: 03:05

That's it. So you can head to speakproject.net, click Friends of SLPs, and all of the information you need is right there, including the link to pass on to people who love us. We have to pay those lawyers and those lobbyists. We need $40,000 now to at least sign the letter of engagement. I went ahead and did that for the CPA firm because I knew SLPs were going to show up.

Jeanette Benigas: 03:36

And they have. But another $40,000 is a big ask and that's only half of what we're going to need to pay them. It could end up being a little bit more depending on how this goes. They're going to be charging some legal work by the hour. So we need at least $40,000 I'm hoping by Monday.

Jeanette Benigas: 03:56

So if you're listening to this when it drops, by Monday. So if the drop date is September 4, I would love to see a total of $80,000 in our Give Butter campaign by Monday, September 7, by the end of the day. That will put us in a really good position to get questions answered that we have, that we need answered by the pros. If we don't get the answers, we are operating on a wing, and a prayer, and AI. And none of us put all of this work into this data project to finish it off on a wing and a prayer.

Jeanette Benigas: 04:35

So please show up, give generously. We're even hoping that our friends of SLPs will donate too. They'll have that opportunity after they submit the letter. So that's where we're at, guys. We need people to show up.

Jeanette Benigas: 04:48

One way we're doing that is occasionally you will hear ads and see ad banners in the FixSLP newsletter. That money through those ads is how I pay myself, a small stipend, and any team member who's being paid at the time. I am going to run a sponsorship campaign. Anyone who would like to run ads on the PhDSLP podcast and in the newsletter, all of that money, 100% of it, will be put into the fund for the lobbyist and lawyer. The one catches, just so everyone knows and we're transparent upfront, I do not have the ability to record offline donations in the GiveButter account.

Jeanette Benigas: 05:38

So I currently have $10,000 from PhDSLP. It's money that I would have been spending on attorneys over the last several months because I stopped doing that once I joined the AMA fight in February. So I just was squirreling away the money knowing that something might be coming and now's the time for that. All right, why don't you tell people who you are and then we'll get into the reason everybody's here.

Emily Watkins: 06:01

I am Emily Watkins. I'm a speech therapist as well and owner of Pediatric Therapy Partners. It's a pediatric private practice in Louisiana where we do speech OT and PT. We also initiated the Speech Therapy Advocacy Alliance on Facebook. We grew to 5,000 members very quickly in the middle of the AMA debacle.

Emily Watkins: 06:22

And my goal is just to keep people informed, engaged,

Jeanette Benigas: 06:25

and advocating for the future of SLP. Thanks, Emily. So the moment we've all been waiting for, what should you put in your CMS comment? We have consulted with quite a few firms out of Washington, D. C.

Jeanette Benigas: 06:39

Over the last month, really since the rates were announced. And we learned in our very first meeting that this data was way more important than making a comment. One of the firms told us, You can get 200,000 comments to CMS, but without data, CMS won't do anything. So the data is now what's going to drive the comments. If you donated data, you are going to hear from Richie May, the CPA firm handling our project, on September 10 with the outcomes for you to use within your comment.

Jeanette Benigas: 07:18

If you did not submit data, starting right now, our platform is open to help you write your comment. So Emily is going to go over how to do that because she put it all together. What we do know is that a template is not appropriate, a fill in the blank form is not appropriate, Every single letter needs to be unique. We helped you with that during the AMA process, but we just don't have the spoons to do that right now, which is why we've delayed this for so long because we have been working on technology behind the scenes that will make this very easy for you and allow you to tell your story. So just like I talked about for Friends of SLPs, we now have a portal for SLPs to go to.

Jeanette Benigas: 08:13

You open the JotForm, there's prompts there, you fill in the blanks with your answers, it will generate a unique letter for you, and then it will email it back to you for you to edit or change as you wish, and then submit to CMS. We will have full directions on how to submit to CMS on the website, speakproject.net, under the SLP tab. We're excited about it. We hope it's helpful. The one thing I do want to mention is that FixSLP will be submitting a report via the lobbyist to CMS.

Jeanette Benigas: 08:51

We have been advised that every single clinician commenting should say in their letter, I support the data being submitted by So when you get the letter back, the very last line is going to have what it needs to say. We request that if you edit, you leave that in because it's going to alert them that something important is coming or has already arrived and that they need to pay attention. The other thing that our lobbyist group is going to do once we hire them is put in an immediate request for a meeting for a day or two following the end of the comment period. Anybody can get a meeting with CMS, but it's important to meet with the correct people. The firm that we would like to hire has experience with this, and so they will get us with the right team and the right people.

Jeanette Benigas: 09:51

So following the end of the comment period, we can sit down with them with the CPA and review the data. The CPA will be there to just talk about how the data was run, the integrity of the data, any technical questions, and Emily and I will be there to interpret the data on how that is going to impact our field and the beneficiaries who receive our services. So again, it's another reason why I need to see $80,000 in the Give Butter campaign by the end of Monday so we can get this meeting request and get it on the books. It's that important. We spent all of this time and all of this effort getting this data.

Jeanette Benigas: 10:35

Now we need to hire the right people to do the right things with it. All right, Emily, I'm going to give you the floor. Can you tell us what clinicians need to do to submit their letters to CMS? I want

Emily Watkins: 10:49

to quickly go over the CMS comment builder because it is going to make submitting a comment so much easier. You answer questions about your own experience, and the comment builder really organizes your answers into a professional and really individualized comment for you. So it starts with basic information about you and your practice, setting where you practice. And then it's really going to branch depending upon whether you participated in the Speak Project cost analysis survey or if you are an SLP or an owner who did not submit data. So if you are a business owner who submitted data to the Speak Project, wait until September 10 to complete the comment builder.

Emily Watkins: 11:36

You're gonna receive that email from the CPA with aggregated data. And so you're gonna be able to look at those findings alongside your practice data and tell CMS things like, here's what it cost to provide a treatment visit. Here's the visit my biggest expenses. How is my practice compared to the national findings. And that is incredibly powerful for CMS to receive that information directly from individual practices.

Emily Watkins: 12:01

If you are a business owner who did not submit data or you are an SLP, do not wait and go ahead and submit your comment now. Here is that question that will branch out. If you click yes, it's going to drop down more questions. If you hit no or that you don't have access to it, it's going to hide those. For clinicians, we're asking about what actually takes place for these services to happen.

Emily Watkins: 12:32

So what happens outside of the face to face treatment session? What are you seeing in your workplace? Next, it goes directly into reimbursement. And so we ask whether you believe that the proposed reimbursement adequately reflects the work and resources required to provide these services. Really, what does CMS need to understand about the proposed reimbursement and why it probably doesn't work?

Emily Watkins: 13:01

So that's what we want you to do. We want you to tell the truth about what you're seeing. If reimbursement goes down, what happens? Do you get a pay cut? Do you foresee SLPs doing more for less?

Emily Watkins: 13:11

Do you see how this will be a struggle to recruit SLPs all and pay them adequately? All of that goes into this reimbursement section. We also want to ask about the new GSLPP g code. If it is relevant to you, we want you to comment on that. If you are not familiar with it or it does not apply to your practice, maybe you're an adult practice because it is only applied to pediatrics, you would say either you primarily serve adults or you're not familiar enough, and it will hide the questions underneath that.

Emily Watkins: 13:47

The last section is really important and is kind of the driving factor, the the drive home section, and it is about what this means. What are the downstream effects of how this is going to play out in actual clinics, your setting? And so it gives you opportunity to explain that. You can choose from the selected boxes, and then you can talk about the real world consequences. The biggest thing here is to be personal.

Emily Watkins: 14:17

Talk about how this is going to affect pay. Talk about how this is going to affect your patients. Talk about how maybe this is going to affect a rural area. Specifically, I'm gonna put that I wanna open in a rural area. I'm gonna put the actual city, and I'm gonna talk about how many patients the actual number of patients that drive from that city to my clinic.

Emily Watkins: 14:35

Those type of real numbers really matter when you are taking these comments to CMS. If there are any other issues you would like CMS to address, we have a couple of options here as well and then a narrative comment box to be able to explain further. The last section is super important. It is what do you want CMS to do? This is the actionable item you would like them to do on your behalf.

Emily Watkins: 15:06

And there are obviously some check boxes up here that will go into your comment. Once you make your selection of the check boxes, you can go in and really drive home one of the areas that you are extremely concerned about and why. If there's anything else we haven't asked, go ahead and put it in there and hit submit. Once you hit submit, it is going to generate the comment. It's very individualized because a lot of the things that you put in there is very personal and individualized.

Emily Watkins: 15:38

And it will send you an email that your drop form is completed. That's the first email that will come from drop form. The second email, just a few minutes later, is going to come from PhDSLP. So make sure you're watching your spam folder for the Jot form. If the Jot form comes, the comment is coming.

Emily Watkins: 15:59

The last thing I wanna say is that you do not have to speak in complete sentences or type in complete sentences when you fill this out. It can be done in very fragmented bulleted points. It is going to create a fluid letter from all of that. The biggest thing, the bottom line of this is use your experiences. And if you make it personal, it's going to come out very individualized.

Emily Watkins: 16:25

And make your comment early. If you're an SLP, an owner that did not submit data to the Speak Project, please do this soon. If you are an owner that provided data to the Speak Project, please wait until September 10, but do not wait till September 14.

Jeanette Benigas: 16:43

I want to remind everybody of a little story. There was a time, just a few months ago, when PhDSLP was leading an open comment period, sending in comments to the American Medical Association. They gave a date. They gave a time. And then everyone waited until the final hour.

Jeanette Benigas: 17:05

But guess what? They closed the window early. So, don't wait to submit your comment to CMS. Now, this is a government entity. There are rules that they need to follow, so if they close before September 14, we could probably file a complaint.

Jeanette Benigas: 17:29

But I don't have a time in front of me. For all we know, they could be closing at noon EST. Don't wait get your comment in before you go to bed on September 13, so you're not blowing up the PhDSLP inbox freaking out asking what you should do, because if they close on the fourteenth before you submit, there is nothing that FixSLP can do. You've been warned. So, please get those in.

Jeanette Benigas: 18:01

While you're at it, as Emily was going over this form, it occurred to me that you can also be sending letters to government officials. You could be using the same form to submit, and we will submit that letter on your behalf, so you don't have to, provided we are able to hire the attorney and the lobbyist team, which I think we will. I'm very hopeful that SLPs will show up, because they always do. It's that important. So, your marching orders are: get your comment into CMS.

Jeanette Benigas: 18:32

The portal is live you can head to speakproject.net, click the SLPs and SLPAs tab, look towards the top of that tab, and you should see what you need to get your comment built for CMS. You can then go to the Friends of SLP tab, get that link, share it with everybody in your practice You do not have to be a private practice owner to do this. You can work in a nursing home. You can work in a school. You can have a cash based private practice.

Jeanette Benigas: 19:03

You could be a mom or a dad listening to this right now and passing it to friends. So what I'm going to ask is every single person who touches this form, please take it and share it to a parent group on Facebook. There are plenty of parents there in those groups, especially the mom groups, write why this is important, and ask people to take five minutes or less to support speech pathologists, because if they don't, we are at risk, in some states, of going away. I'm thinking about Kentucky, where the Medicaid statute is 63% of the published rate. At a 40 something dollar rate for language, I'm not sure how you do that.

Jeanette Benigas: 19:50

So, please, share, share, share, share, share. In a month, we were able to generate nearly a thousand comments for the AMA comment period. That is the most comments they have ever received in the history of the AMA, according to our advisors that we were working with. Let's do it again for CMS. I have heard a few people freaking out.

Jeanette Benigas: 20:15

How are you ever gonna get a thousand letters? Listen. Listen. Let me let me give you a live update here. As of right this moment, in the last two weeks, we have raised $44,970 on gift butter.

Jeanette Benigas: 20:31

Okay? SLPs show up, and a lot of us have ADHD and are neurodivergent, so we're showing up at the last hour anyway. Just make your last hour September 13. So, you know, it's how we roll, right? Oh, it just crossed to 45,000.

Jeanette Benigas: 20:49

See that? As we speak. This is dropping on the September 4. You have ten, let's call it nine. You have nine days to get your comment in.

Jeanette Benigas: 21:01

The Friends of SLPs is going to go beyond the fourteenth, we believe. Right now, and I are planning that deadline to be the very last day of September, September 30. It will shut down on the October 1, and it won't be accessible anymore. That is pending confirmation from the lobbyists once we're able to hire the team. Again, we're shooting from the hip here until we're able to pay for advice.

Jeanette Benigas: 21:30

So parents and families and friends of SLPs will have much more time to contact government officials and put the pressure on, but we need them to get started now just in case the lobbyist comes back and says, No, we shouldn't be contacting them after September 14. So please get your comments in, spread the word, give generously, and we will see you next time. Thanks for fixing it. Thanks for listening to the FixSLP podcast, the podcast shaking up you help out. Supports our you PhDSLP team.

Jeanette Benigas: 22:16

We're Don't just listen. Be a part of the change. Share this episode and our social media content, and let's keep fixing the field one bite at a time.