Fix SLP: Advocacy & Accountability in Speech-Language Pathology

92507 is changing, and SLP documentation will have to change with it.

In this episode, Jeanette Benigas, PhD/SLP, is joined by adult and pediatric private practice owners Katie Brown, MA/SLP, and Emily Watkins, MCD/SLP, to talk about what the new code set could mean for documentation, billing, compliance, and audit risk across pediatric and adult settings.

Katie and Emily share firsthand experiences with Medicare, Medicaid, and commercial insurance audits, including what payers requested, what triggered the audits, and why documentation supporting medical necessity and skilled intervention matters. They also deliberate one of the biggest shifts ahead: moving from a catch-all code to multiple service-specific codes means SLPs will need to clearly support what they treated, why it required skilled intervention, and the time spent providing that treatment.

The takeaway: do what you bill, bill what you do, and document what you do.

Whether you’re a clinician, manager, or private practice owner, now is the time to understand the changes and prepare... before January.

Resources Mentioned
👀 Check out Katie's SLPs Blueprint to Medicare Success and get $100 off with the code FixSLP
🎧 Previous episode with Emily Watkins: CMS's NEW Pediatric G Code Explained: What Every SLP Needs to Know
🎧 Previous episode with Katie Brown: What the New Speech Therapy Codes Mean for Adult SLPs
🎧 Previous episode with Katie Brown: Telehealth Coverage Expired: SLP Rules for Medicare Claims
🎧 Previous episode with Katie Brown: Telehealth Under Threat: Protecting Access for Adults and Families
▶️ Watch the Fixing the Coding Chaos series, or this episode on YouTube

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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:

Welcome to FixSLP, 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. Hey everybody, welcome back, it's Jeanette.

Jeanette Benigas:

I've got two guests today. We were talking before I hit record that we think out of the entire 92,507 series that we've been doing, this is now that we know these codes are happening, so now since we know they're happening, this is probably the most important episode topic that we've done, that we have planned so far, because this is going to make or break our employer's ability and then by extension our ability to make money. And it's a serious concern that we have, a lot of other business owners have, a lot of other people familiar with the insurance process has, and we just need to talk about it so everybody's ready. Because who knows, like in adult world, we've said in the last podcast, most of our employers probably don't even know this is happening yet. So this is going to be a last minute, it's Christmas time, everybody attend these trainings situation.

Jeanette Benigas:

So we're talking today about documentation and auditing and how the new code set may open us up to more audits and therefore documentation needs to change based on the new code set. So before we jump in, I just want to say thank you to Mr. PhDSLP, who has been amazing this week. My husband, John, we are on vacation. He took the kids and, of course, it's raining, so he couldn't take them down to the beach, so he has found somewhere to take the kids out of this condo so I could record without a ton of extra sound and disruption.

Jeanette Benigas:

He has tolerated meetings and phone calls as we've tried to get this advocacy effort and what to say to CMS off the ground. And so, it seems like every time we go on vacation something like this happens. I surprised him over two years ago with a trip to Mexico and I forget what it was then, but something happened and I was sitting poolside on my phone fixing SLP. So, he's always very good about it, so just shout out to him. Alright, so today I have Katie Brown back.

Jeanette Benigas:

If you didn't listen, last week we talked about adult issues with the new code set, but it's not just for adults. We have a fearless fixer who's been following for a very long time who reached out very complimentary and said, This is probably the best episode you've ever done. Okay, thank you for that. So please, you don't have to be an adult SLP for it to be applicable to you. Please give it a listen.

Jeanette Benigas:

So that was adult. And then the week before I had Emily, we talked about pediatric issues and Rick Gawendo was also on that one. We talked about the, sorry, you're watching from home now, I'm trying to do video. I got hair. Okay, we talked mostly about that G code that is pending for the pediatrics doesn't apply to adults.

Jeanette Benigas:

Give that a listen. If you're an adult SLP, don't skip it. Yes, the G code doesn't apply, but there's still plenty of other applicable information. So, ladies, thank you for coming back. I am a business owner, I am a long time clinician, but I don't deal with audits and reimbursement and documentation from a business owner's side.

Jeanette Benigas:

I have dealt with it from the other side, and I think I've shared it on the pod before, but I'll share it briefly again, a time when one of my charts was audited by CMS and money was recalled and how my employer dealt with that situation. I think we all are in agreeance that these 10 new codes, which for our purposes we will just call today five codes because the documentation will be the same whether it's a base code or an add on. So we've gone from one catch all to five specifics plus we can say there's still dysphagia, cognition, and AAC. So in total maybe eight that we would have to, I think, document very accurately on. So just because Katie right now on my screen is on my left, we'll go left to right.

Jeanette Benigas:

Katie, why don't you tell everyone who you are briefly, where they can find you and what you do, and then we'll go to Emily.

Katie Brown:

Yeah, absolutely. Thanks for having me back again. So I am a medical speech language pathologist and private practice owner in Buffalo, New York. I own the practice Neuro Speech Solutions, and you can find me on Instagram neuroseechsolutions. I also have a website where I have lots of freebies and blogs for SLPs related to medical SLP topics.

Katie Brown:

And I also have a Medicare for SLPs program that teaches private practice owners how to bill Medicare Part B as well as compliance and documentation and all of those types of things. Documentation has always been at the core of what I think is super important for SLPs to be able to do. First off, efficient documentation, so that way we're not always just sitting there and bringing our documentation home, but also smart documentation that checks all the boxes for compliance. And that is a major concern, which is why Jeanette was, you know, kind enough to have me back on this week.

Jeanette Benigas:

This is time number four. You get, like, a reoccurrence trophy at this point. Sending you a Christmas tree ornament. I'm excited. She was humble enough not to say it, but she has, she does have a code.

Jeanette Benigas:

Shared FixSLP is the promo code that she's offering our listeners a discount, and then, even more generously, gives us a very small percentage of your purchase. So it helps support me and anyone on the team that we're paying. And so we all really appreciate that. So, all right, Emily. How about you?

Emily Watkins:

Okay. I'm Emily Watkins. I'm a pediatric outpatient clinic owner in Louisiana, so you'll probably hear our distinct accent differences. But I opened in 2018. We do speech OTPT.

Emily Watkins:

My I didn't say this the last pod, but our website's ptpoofla.com and I also am a, like I said, speech therapist by trade. I always have to say that because I'm at conferences and nobody ever knows. So I am a speech therapist by trade, Haven't treated, you know, intently. I'll step into some evals every now and then or they're trickier than others, but haven't treated a caseload in a couple years. But through this advocacy effort, these major changes in our profession, I met Jeanette and she has introduced me to a ton of people who are just very bright, brilliant.

Emily Watkins:

They're doing so much to change the profession for the best. So I'm very thankful to have met her in her network and feel blessed to be included in her in her circle. But I, you know, also decided to start this Facebook page because I felt like we needed a national page to where people could collaborate and make comments and and give ideas because there's been some really good ideas that have come up and people that I've talked to that I never would have met before or wouldn't have talked to. So I think it's been as much of negative that people think that this is. And it's not like change is never wanted.

Emily Watkins:

We don't ask for like, oh, let's just change our entire profession and how we document and how we're gonna operate. However, I do feel like the perspective is important to the change is good. In many ways, is good and it brings a lot of people together and it has introduced me to a lot of people. And so we have that Facebook page. It's Speech Therapy Advocacy Alliance and I would encourage anybody to get on there.

Emily Watkins:

I did have to take it from public to a little more private because we're getting some ads, but for the most part it's been really great and it's been great to be able to disseminate information that otherwise wouldn't have been able to be as easily disseminated. And so I would encourage everybody to join that and collaborate with us.

Jeanette Benigas:

And it's a great group. Katie, why don't you tell us, let's just start with your story, your business's story about the audit that you went through through Medicare. I think you said at one point that you never expected Medicare would audit you, but they did. This is really important. These are CMS codes.

Jeanette Benigas:

This is Medicare. So Medicare does do this. It's going to apply to commercial insurance plans and all of those things. So that's why we have Emily here to talk about that side of it too. But I mean, these are their direct codes, and this is what they do because this is how they save money.

Jeanette Benigas:

Yes. Right? All right. Tell us about your story.

Katie Brown:

Of course. So like I said, I 100% never thought Medicare would ever audit me. I mean, I'm small fish, right? At the time that I got audited, I had maybe four full time SLPs. Mean, can't I'm not a large practice.

Katie Brown:

So I thought, We're good. It doesn't really matter. I wanna do the best I can to have everything and have all my ducks in a row and make sure that all of my documentation is there. However, the likelihood of them actually auditing me was unlikely, but then it happened. In the end of twenty twenty four, I think it was October 2024, I got the dreaded envelope.

Katie Brown:

Anyone who is contracted with Medicare, you know that a colored envelope means Medicare is wanting something from you and it's typically negative. So you'll get colored envelopes if there was an overlap in home healthcare and now they're taking payment back. You will get a colored envelope if they are telling you that they are going to audit you. And that's what I received. So I received a request to send information.

Katie Brown:

Essentially what they do is they say, These patients for these date of service by this provider are affected. You need to send us all documentation that is for these dates of service for these patients. So I believe that they audited, I think it was like 12 patients or so. They didn't say, You need to send us everything and you need to send us all of your documentation from your business. They selected several patients.

Katie Brown:

In particular, my audit focused on initial evaluation and some follow-up sessions after. And I needed to provide all documentation for that. I needed to provide the support that these services were warranted. Scripts from doctors, if I had them would support that. I needed to send signed plan of cares, which is something that has notoriously been challenging for SLPs to obtain is that signature on that plan of care, that initial plan of care for our patients.

Katie Brown:

Because trying to chase down a physician to sign a piece of paper is almost impossible. So I received that and immediately panicked. I received it for requesting for patients years prior. So I received it in I'm going to say October 2024. All of the documentation was for 2022 that they requested.

Katie Brown:

So they don't say, Hey, last Thursday's visit, we need this. They're going to go back retrospectively and request the documentation there. So, you know, you can think to yourself like, Oh, I'm gonna be safe because, you know, a few years ago they haven't asked for anything yet. No, you to have everything outlined. It was a very strenuous process because it took quite a bit of time to get all the documentation, to send it out.

Katie Brown:

And then of course there was the waiting of when am I gonna get the response back from Medicare? Are they going to take money back from me? What did they find wrong? I can say that luckily I had a 0% error rate is the they way do it. So they didn't find anything wrong with my documentation, which is so fantastic.

Katie Brown:

Very happy about that. Honestly, like I said, documentation is like one of the pillars that I talk about with all of my clinicians that I talk about whenever I'm educating other private practitioners or SLPs. Our documentation has to support what we're billing. And before we were billing 92507, which was an umbrella code for basically anything that we did besides swallowing. And now our documentation is going to have to match the code that we're billing.

Katie Brown:

One of those five parent codes, one of the five base codes. We're gonna need to make sure that whatever is documented matches up. Your documentation must justify whatever it is that you're billing. And SLPs didn't need to necessarily deal with that before. We didn't need to say, Oh, well, I did eighteen minutes of language and sixteen minutes of speech before.

Katie Brown:

This is our reality now and we're going to have to get used to it. And at least I know for myself in my practice, we're starting now so that we get used to it before January hits when it really matters.

Jeanette Benigas:

As an educator, this is where I bring a little thought to this, students aren't being taught any of this. I mean, it's not a blanket statement. There are university programs who certainly are doing a good job. So students are going to come out of school with a growth area in this, and they're coming to us, the practitioners who have never had to do this. I think there's going to be a lot of growing pains in this area because I always bring it back to, as I think about this, we always say nobody knows what we do.

Jeanette Benigas:

We spend half of our time in hospitals or schools educating people about what we do. And I've said for years, half of the time, I don't even think speech pathologists know what we do. We make stuff up, we go with what we feel. And again, this is not everybody, so please don't get offended. But I'm someone who has done PRN in hundreds and hundreds of nursing homes over the last seventeen years.

Jeanette Benigas:

And I have made that my full time job. I have never been full time as an adult therapist in one place. But whenever I have wanted full time hours, I have achieved that. And in more than one instance, hit overtime. I have hit overtime.

Jeanette Benigas:

I've gotten $5,000 paychecks from multiple companies because the need is that great, or at least was back then. So, I just had this conversation where in one of the adult groups, in the SNF group, somebody said, the pattern in nursing homes is that we only treat dysphagia. And I was like, you don't treat aphasia or cognition or motor speech or woah! And she described the same scenario that I have with how I work, and she said, I'm surprised you're even asking this. You must not be in nursing homes that much.

Jeanette Benigas:

No. Like, actively still in nursing homes. Still. Today. Even through all of my teaching, still.

Jeanette Benigas:

So that must be regional or specific to that little area. But generally, we should be treating all of those things. And so I have seen documentation for all of those things across many clinicians, many students, as I've taught and supervised. It worked for ninety two thousand five hundred seven because what you said, Katie, is it's like a catchall. But now, SLPs have to know what we're doing and why we're doing it.

Jeanette Benigas:

Or else, once we figure it out, we have to add another eval on. And I think some instances, Katie, this might even be different in a nursing home. I think it is for Part A, which is not what we're talking about. I don't even know if that's reimbursed necessarily. I don't know.

Jeanette Benigas:

Emily's saying no. If we have someone who has aphasia and we sign them up for language treatment and dysphasia treatment. But then three weeks into it, we're like, Oh, there is definitely an apraxia happening here. We can't just start treating apraxia. We have to go add that on to the plan of care through an evaluation that shows that that is a problem and then add it on.

Jeanette Benigas:

Which is extra work and lost therapy time. So that's just one example of how we've been able to kind of pivot. Like before, maybe we could just do a quick UPOC or an addendum and add a goal or two, or a progress note and add a goal. Whereas now, no progress note, I don't think, ladies, you can correct me, a progress note isn't going to cut it now. We have to have the evaluation that shows the need and then write the goals to get the reimbursement.

Jeanette Benigas:

Am I right there?

Katie Brown:

Yes, to my understanding, yes. One thing in particular is we need goals to match up with the billing codes. So if normally you bill language and then, like you said, suddenly, oh, there's an apraxia, I want to bill speech and language, but there's nothing to support speech in your plan of care, then either your plan of care needs to change or you're not billing for speech and language. And I think that is an area that we've been fortunate to not have to worry about that. You know, SLPs have a lot of things to worry about, and we haven't had to worry about that, but now we're going to have to.

Katie Brown:

And everyone needs to know that. And you know, I said in the last podcast, there are still SLPs that don't even know that these codes are being changed.

Jeanette Benigas:

Happened last night. Yeah. Spread one last night. Somebody what? Somebody sent somebody tagged me.

Jeanette Benigas:

That's like, how is this still happening? Yeah. Yeah. How? How is this still happening?

Emily Watkins:

Now I was gonna say on the private practice side of that is that no, we haven't had to go back. I mean, all we do is we don't have to do a progress note. We can just go in there, change goals because thankfully, I can kind of have been able to make the own, like some own rules. I'm not saying like billing rules, but for stuff like that operationally, we don't have to. Now my OTs and PTs do.

Emily Watkins:

And so that's that's the the blessing that I have is I have their lead in the way that they've operated for years or ever since I've been open. And so that's the one good thing about me having them to lean on. Now granted, they're on fifteen minute increments. This is gonna be a thirty minute, so that is very different. But I do agree.

Emily Watkins:

I mean, that is one thing that I have a clinic director here. She's an OT. And what you just said, you have to have a goal that matches up your billing. And if you don't have one, you can't bill that code. And so they are they are adamant about that.

Emily Watkins:

They train it, she said, really well in school. I think they have an entire class in OT. I think OT even does it in my limited opinion from the schools around here. They've done a really good job of when we get OT students, they know. Like, they are very well versed in the fact that they have to have an activity log.

Emily Watkins:

They have to have an activity log that matches the minutes, that matches the goal, that matches the billing code. Your EMR system, it's not gonna say the best ones are the ones that cost the most money, but typically, the money matches the value in that situation. So your EMR system, dependent upon how invested they are and and well versed in what's going on is gonna be able to help in some of these instances. However, it's the human error that we all are very concerned about. And and I think it's valid, know.

Emily Watkins:

I mean, we were going from like you just said, I call it the umbrella code, catch all code, umbrella code, whatever you wanna call it. And we're now splicing that into five different billing codes. And as much as that is from an operational standpoint, a nightmare. From a data standpoint, I love it because we wanna I wanna know how much of this we're doing and how much of this therapy we're doing. And then I would love to know the outcomes of these individual therapies or when they're combined, do we have better outcomes?

Emily Watkins:

Okay. Well, we can get paid more for that if if that's the case. So there's all kinds of great things that will come of this if we can just get through the tough part, which is the change. And so you gotta get your mind right basically on we're going from a catch all umbrella code to these five codes and then how do we justify that? We've always had to justify while we're building a code.

Emily Watkins:

Like, that that's not going away. It's the fact of justifying now the minutes. And so I think that's important if you can understand that we're you're still justifying, but you're going to have to say that my documentation justifies spending sixteen minutes, thirty minutes, thirty eight minutes, whatever it is that you end up operationally working by. You just have to be able to justify that amount of minutes. So if the kid does five trials on and I'm talking from a peds perspective here on a speech sound, there's no way in in the world that an insurance when they if they audit you can pull that and go, well, I can't pay you thirty minutes for that.

Emily Watkins:

Right? So you are going to have to prove that you are working or not just seeing a kid because they were late and they were twenty minutes late and we saw them for ten minutes. I mean, we had that happen this week. The therapist came and said, hey, they're fourteen now into fourteen minutes. Do I just cancel?

Emily Watkins:

And I said, yes. Because I cannot justify. I don't I don't care if the parent wants us to see them. I we can. I can see them all day long, but I can't bill for it.

Emily Watkins:

And so that's the thing is that we're gonna and but but you technically could. You technically could. I'm just not doing that across the board with fourteen, eighteen speech therapists that I have. I'm not doing that because then that just becomes the norm and I'm not gonna have that become the norm. So again, it's all in the fact of having to justify your documentation.

Emily Watkins:

It's just one step further in saying, okay, well, what did I do to be able to justify that sixteen minutes or that thirty minutes, whatever it is that you're doing, but you're gonna have to justify sixteen minutes of therapy to be able to bill a code. And so that's gonna be kind of the challenge.

Jeanette Benigas:

I'm glad you brought that up because I was thinking about this in preparation for today. I was thinking about what are some of the challenges that I could see happening. And what I could see happening is that as a speech therapist, we know we're going to build voice and cognition. Or how about language and cognition? We're going to do those two.

Jeanette Benigas:

I could see me or anyone else walking into that session, doing what I always do, and then billing sixteen and sixteen, right? Technically, that's not ethical. We need to make sure we're spending 16 on the language and 16 on the cognition and that we're showing that in the notes. And the example Emily gave, oh, five trials of whatever, that's not sixteen minutes. Unless you are documenting like crazy how the person struggled and the cueing you gave.

Jeanette Benigas:

And so I think some of this language, like min, mod, max, cues might not cut it anymore if you have someone who's only doing five trials and you're saying you're billing sixteen or thirty minutes. I see that a lot. We tend to do three out of five trials or five out of five or 10 out of 10 or eight out of 10 with eight out of 10 accuracy, whatever. Who's getting better in 10 trials? I say this all the time and I always go back to dysphasia because my own practice has changed a lot over the years so I can look at back at what I did to what I do now.

Jeanette Benigas:

And this is what I tell my students. If you wanna get a six pack, you are not going to the gym and doing 10 sit ups and going home. And so that's the equivalent of doing 10 chin tuck against resistance or 10 effortful swallows and calling it a day. We're not getting any one better in 10 trials. So if we're really focusing on these things, we are going to have to up the number of trials we're doing with people, and if they're lower, document why it took so long to get through those trials.

Jeanette Benigas:

And this is across the board. This isn't swallowing or language. This is across the board. If we're not documenting a session that's showing that robust treatment for the number of minutes we're saying we're doing it, they're going to see right through it. And maybe not at first, but AI is coming into auditing and AI is going to know.

Jeanette Benigas:

They're going to know another one I see not as much anymore, but for cognition where I did this. I did this in my clinical placement as a student. We had cognitive patients coming in and we would put down three playing cards or five playing cards and we'd make them memorize where they were and shuffle them up and then give it to them and now you have to lay these out in order. Memory is not getting better by doing that, okay? That is not cognitive therapy and AI is going to start pinging that because AI can find the evidence and know.

Jeanette Benigas:

And then it's just going to build, I don't know this for sure, but I can just imagine it's going to build an intelligence and a catalog of things that is evidence based and not. And yes, clinician experience and patient values are important. And so if you're bringing that into your evidence base and that is part of why you're doing what you're doing, you need to document that too. Because humans are going away and computers are going to start doing this job. So we, again, have to know what's the problem, what's the modality we're choosing to help compensate or restore that problem?

Jeanette Benigas:

And what are we doing? And what's the intensity level and frequency that we're doing it at to make sure we're justifying our skilled service? And that's the key. What are we doing in that room that's skilled? That man's wife could have shuffled a deck of cards, right?

Jeanette Benigas:

Why do you need me with a PhD or Katie and Emily with a master's degree to do this session today? We're not very good at that.

Katie Brown:

Yeah. I've been biting my tongue as I'm listening to you because I wanted to jump in a bunch of times, but you just summed it up perfectly. We need to document skill. Why? Why are we providing this treatment?

Katie Brown:

You're exactly right. Why isn't the spouse shuffling the deck of cards? Because the spouse can shuffle a deck of cards. I have always thought that a lot of documentation, like you said, eight out of 10 with mod cues. What are mod cues?

Katie Brown:

What do you mean? Insurance looks right through that. They're like, There's no skill to that. In order to bill to insurance, we need medical necessity for most, right? Let's just talk about Medicare.

Katie Brown:

We need medical necessity and we need skilled therapy. So if you're not documenting your skills, you are opening yourself up to clawbacks. And that's not the reality that we want. And that's where I think a lot of people's documentation needs to update and kick it up a notch. I'm not saying you need to write a novel, but I am saying don't say mod cues, say, Well, we did modeling and placement cues, and then that faded out.

Katie Brown:

And then they were able to benefit from just a mouthing model rather than actual sound. We need to substantiate why we are using our degree for this therapy.

Jeanette Benigas:

And if you go back and listen to the last week's episode with Katie and I, I did hold back tears and then some fell. As I talked about losing our profession to OT and PT. And you just heard Emily say, OTs and PTs have been doing this for years. They are better at this. So they're already doing this.

Jeanette Benigas:

They're already doing it in our adult world with cognition. And if there's going to be audits and money's going to be pulled back from SLP, but it's not getting pulled back from OT who's treating the code, us or them. We need to think about this as also protecting our turf and our profession. And I had a really disappointing comment on something this week too. That said, I'm tired of you as in me.

Jeanette Benigas:

I'm tired of you putting this on SLPs. I am a single mom who needs the money, who can't afford to start a private practice, who needs a job. First of all, I never said you need to start a private practice. So let's get that out of the talk. Okay?

Jeanette Benigas:

Let's get that out of our language. What we are saying through all of these podcast episodes and posts and information is this is everyone's responsibility. It's your employer's responsibility to offer training so they make sure that they get the revenue they need, But it's also your responsibility to get yourself educated as a professional to make sure you're doing the job right. And that's not just to make money for your employer or make a paycheck for yourself, but it's to serve your students and your kiddos and your patients and your clients well so they can get what they deserve. Because if you're not documenting correctly, has anyone done Advantage Plans before?

Jeanette Benigas:

They'll cut you in five minutes, okay? If someone's gonna go back and appeal a decision that's been made, that comes down to your documentation. And I venture to say appeals are lost more than they're won. So this isn't just on SLPs, it's on all of us. We all have a different role to play and your socioeconomic status, your job status, whether you own a business or not, doesn't come into this at all.

Jeanette Benigas:

It's about being a speech language pathologist who knows how to do the job and does it well or is taking ownership and learning to do it well. And I've done that work. When I started treating in nursing homes, I quickly recognized I had no idea what the F I was doing. I've shared this on this platform before. I've shared the fraud that I knowingly committed.

Jeanette Benigas:

So you all know that I've been in your shoes. And I went and got educated so I could be better for the people I'm serving. And honestly, when you're better at the job, it's more fun because you see more outcomes. So these people who say cognitive therapy isn't real, it's because you're not doing the right cognitive therapy. You haven't learned how to do it yet.

Jeanette Benigas:

And that's okay because we're all learning everything at different rates. The goal here is for all of us to get better and to make our profession better. And I'm gonna pivot to Emily now so she can talk. But this is not for today's podcast, but Emily and I are working on a huge project that will have implications, we hope for now, but for also every year in the future that Medicare or Medicaid across the board tries to make cuts. She's got a meeting in a couple hours about this.

Jeanette Benigas:

So hopefully next week or the week after we're bringing this to you. It's not ready to go yet, but it all plays into this how to comment to CMS thing. But what that is going to rely on is accurate data and accurate reporting. And I even did some self reflection as I was getting ready for this because as Katie and I said in our podcast, we brought some positives to light too. It wasn't all doom and gloom.

Jeanette Benigas:

And I was like, has your attitude shifted? How was this ninety two thousand five hundred seven change bad and now suddenly it's good? And it's not that my attitude has shifted, it's that it has had to shift. Because as Emily had said, none of us want this, right? None of us wanted to go away from 92507.

Jeanette Benigas:

These five codes and these five add on codes were not going to be good. We lost. It's happening. So now it's not that I personally have changed my perspective. I still hate this.

Jeanette Benigas:

It's that this is happening whether we want to or not. And so now we have to find the good in it. We have to take the lemons and make the lemonade and figure out how can we use this as an opportunity to improve ourselves and our profession and maybe on the other side of this, even stronger than we were three months ago. All of this is going to come down to accurate data reporting. That's on all of us.

Jeanette Benigas:

So Katie has shared how this has impacted her. Well, or actually it was just the stress and the time and maybe the money for admin that it impacted. Thankfully, you weren't paying money back. Emily, tell us about your auditing story.

Emily Watkins:

Okay, so I have a lot. I've done early intervention before I opened my practice. I got audited there. A lot of speech therapists in the early intervention will do like paper documentation, and I knew that I was just not good enough to keep up with that for five years. So I've got a digital platform, did signatures, parents would sign on the iPad, things like that.

Emily Watkins:

So if you're an EI, I would also I mean, this goes from early intervention, EI, I'm gonna say it that way, to private practice, to schools, to anything. I'm just gonna talk from pediatric. I'm not I can't I've never been in the schools from a working sense, but y'all heads up, that's gonna this change is gonna happen right in the middle of your school year. So again, that's gonna be another shakeup if they haven't thought about that. But from an e I perspective, I got audited, sent everything in, and then everything was cleared.

Emily Watkins:

I think the biggest thing if people can wrap their head around documentation is consistency. Is consistency in when you do it, consistency in how you do it, consistency in why you do it. My company is very core value based and mission driven, and one of our core values is discipline. And I am not good at discipline. I am not good at, like, if I'm gonna go work out, I'm not doing it at the same time, you know, all of that.

Emily Watkins:

But when it comes to compliance, is, one of the biggest values that you can have and things that you can just get locked in now is doing it consistently. So when? Do your documentation at point of service if it's possible. Peds, it's a little harder if you have a kiddo that's a little more behavioral or you're having issues or they're all over the place. But 80% of our patients in our clinic, you can do point of documentation and that is the best documentation or at least to get most of it in because your memory is right there.

Emily Watkins:

You're not gonna forget something. You're gonna be able to know how many minutes. You're not gonna do it in three more sessions and think, gosh, I don't remember how many minutes I did that. So those things are gonna get harder as the time between when you did it and when you're documenting. So again, consistency in when you document, consistency in how.

Emily Watkins:

That is really important too because again, I did documentation very consistently. All of my audits have gone pretty well. And so again, the how, you know, like how are you documenting and doing it extremely consistently cause payers like that too. If you show that you're very consistent in the words you use, and not necessarily pulling forward words, I'm talking about medical words versus, Katie just said it, mod, those type things. If you're more detailed in how you're doing it, then it just becomes a habit too, but also it's the consistency in it.

Emily Watkins:

So that would be my biggest takeaway is just get super consistent, get trained, get a standard. We have standards at our company where they have to be followed. And so I didn't tell my audit story. I guess I'd go back and say that, but EI, I've had an audit. I've had multiple audits from Medicaid, Blue Cross.

Emily Watkins:

I mean, I've had them all across the board. That was mainly because I grew so fast and the Blue Cross told me there's no way you grew and didn't acquire a company. And I said, nope, I didn't. And they literally went back and forth with me. It was during COVID, we went 230% year over year for like three years, I think.

Emily Watkins:

And so when you have things like this, there are triggers in their system that happen. So if you build certain codes together a lot, that doesn't mean it's wrong. I had an audit from that. I mean, Cross taken back. They're trying to take a $120,000 back because I build two things together and they put their NCCI edits in thirty days before it was also in 2024.

Emily Watkins:

They went into effect in 2025. So audits, I mean, they're not fun. I'm not gonna like, oh, let me have one. I don't want one. But I also think there's a way you can deal with them and handle them.

Emily Watkins:

And if you can stand on the fact that you're doing things correctly and you know you are, then they're not as scary as they seem from the outside. Because again, knowledge is power. If you're anxious, you're worried or whatever, just gain the knowledge and all of that fear and anxiety goes away. Just a little pro tip, when I get audited, I just call them and I say, what do you need? And I ask them a ton of questions and sometimes they give me zero answers.

Emily Watkins:

Okay. They tell you no. I'm not gonna tell you anything. But sometimes the Blue Cross one, they told me exactly what they were looking at. Called Rick Goenda, and he called me back at like 8PM one night and he was like, you have nothing to worry about.

Emily Watkins:

Why are they even sending you this? These are allowed to be built together. Sometimes just call and ask questions. Pro tip, because a lot of times they'll give you some information. You'll get somebody who will give you the information.

Emily Watkins:

I've gained a lot of info by just calling. When asking them, what do you need? Because then we don't send them more than what they need because they use that to their advantage. And quite frankly, we're human and we make mistakes. And I don't want them to use any of my human error mistakes to their advantage.

Emily Watkins:

So that's just another little pro tip and we could do a whole thing on how to deal with an audit if we wanted to. It's really not sexy, just like documentation's not sexy. But it's important to know not only how to deal with it, what happens in it, but then like how do you learn from it? Because that's again, that's why I am very consistent in my documentation and how we train. I mean, is the day one training is our documentation, EMR system.

Emily Watkins:

We have it set up to where things are required, so it makes the human error lower. We try to do that as much as you can. That's another thing is just try to get that human error just reduced down to as little as possible, especially in this change is gonna be huge. So if you're not super compliant, you don't know what's required for your Medicaid, you don't know what's required for your documentation in for Blue Cross, whatever, I would go and find that out. ChatGPT is a great resource.

Emily Watkins:

Rick Goenda is a great resource. Go find that out. I would do that now. And then start doing it because when a change comes, if you're consistent, it's a lot easier to deal with the change. I did wanna make a comment too about how you said the cog being pulled and OTs are gonna treat it.

Emily Watkins:

So I'm a speech therapist. I believe that our speech therapists are very well equipped to treat swallowing and feeding. I'm just gonna say that as a, like, a preface to what I'm about to say. But our feeding and swallowing code is bundled because it's two untimed codes with 92500And7 and the feeding code. They're bundled in my state, so we don't get reimbursed for it on Medicaid and Blue Cross.

Emily Watkins:

So with that, as an employer, I have to go, OTs get paid for that. I have to spend a lot of money training. I mean, I spend I do not let anybody who walks in my door treat feeding. They cannot treat it when they walk in my door. They have to have a certain level.

Emily Watkins:

We have tears at my company and you have a certain level that you have to have before you can treat a feed. Okay, that costs money. And so I have to look at that and go, where is my ROI? Where is my money spent on training? And so like our speech therapists do not get a lot of training and feeding.

Emily Watkins:

They get a very, very low and they really don't treat it much because I can't get reimbursed for it when you add up the cost of training to that and the liability and all of the things. And so, yeah, my OT's treated way more. I'd say 90% more. Now when this code change happens, that probably will change and I want it to change. Be I'll honest, that was one of my things I was actually kind of excited and Rick going to look at me at a conference.

Emily Watkins:

Was like, you're excited about these time codes? And I like, yeah, maybe my speech therapist can finally do feeding like they're trained to do and get paid for it. You said that example from an adult standpoint. I'm giving it to you from the the horse's mouth as to why you decisions have to be made that way. And it's and and I don't want it.

Emily Watkins:

I mean, they we talk about it all the time. You know? How I I I'm like, we're very well trained. I I personally think we're the best at it. But it's a decision that you have to make based on how the company, the ROI of everything.

Emily Watkins:

And so that's the thing is I think that as negative as changes are, because nobody likes it, it forces you into some positives that you didn't really know that were gonna happen because people don't realize I mean, there's a price some people don't even realize that it's being bundled in their state. They just oh, that's never been paid. Well, why? Why haven't you fought that?

Jeanette Benigas:

I wanna interrupt you. Yeah. Because I already know this answer. I'm sitting here laughing, and I'm thinking about all of the social media reels I can splice together from this. Emily, did you listen to the episode that Katie and I did last week?

Jeanette Benigas:

No. Thanks for making our point. You literally just made the point that we were driving home, that I'm crying on a podcast saying your employer is gonna pick the person who makes more money. And you just said, as an employer, I have to look at return on investment and cost. And I give it to OTs.

Jeanette Benigas:

Does everybody hear this? Go back and listen to Katie and I last week. It was an adult named podcast, but Emily does pediatrics and she, from an employer standpoint, without even knowing that Katie and I had the whole conversation about how adult medical SLPs are in trouble, she just gave you the example. It's already happening. It's happening in front of us and we are losing this profession for many reasons.

Jeanette Benigas:

And this is one of them. So please go listen. Please.

Emily Watkins:

But we're not gonna let that happen. No. Because we're gonna get data. Yeah. Data is important.

Emily Watkins:

And I hate to I'm not gonna disparage anything necessarily, but ASHA has an initiative and they have a system that we, I have tried to use and I have had meetings with them because I wanted to use the outcome measures system. They have, like, 2,000 patients in there at any given time. Out of the hundreds of thousands of speech therapists that could be using it, it is so hard to use. It's so clunky. It is so difficult.

Emily Watkins:

I said, I'm just gonna make my own system and deal with and do my own outcome measures and and have my own for my own company. And so what I'm saying is is that there is no data. There is no data that says that a speech therapist doing feeding gets better outcomes because unfortunately, our national organization has not developed that, has not advocated towards that, and has not cared to gain that data. And in my opinion, we're getting into the age it's just not my opinion. We're getting into the age that data is power.

Emily Watkins:

It is more powerful than anything else. And when you can have a trend and you can have data and you can show unbiased information to another person or a company, that is going to win all day. And so the more that we can get on board with that and understand that as a profession, the better we're going to be in a year, two years, twenty years. But if we don't, then we don't have the data. We don't have any power.

Emily Watkins:

And so it's just it's so important to understand that that you've got to be able to collect the data and to be able to go and say, this is why this is valuable, and this is why we are valuable, and this is why our valuation isn't where it needs to be. Only way to do that is through data. It is You can argue with me all you want but that's the only way that it is going to change and the only way you're going to increase value which is a number is through data which is a number.

Katie Brown:

Absolutely. I mean just to jump in there. CMS, AMA, ASHA, Medicaid, powers that be are not going to just magically give us more money because we say we want more money or we deserve more money without actually quantifying that number. And Jeanette and I had spoken on the last podcast that this does give us an opportunity to track outcomes better. Just like you were just saying, Emily, I think that if we can think on a bright side, doom and gloom of we will be able to parse things out better and get that data and that trends to support in the long run.

Katie Brown:

Is it going to happen tomorrow or January? No. But I'd say the future and the outlook is brighter in that sense.

Jeanette Benigas:

And Emily and I are going after that. Again, meetings today. Hopefully, we have some answers in the next week or two. I want to wrap this up in a package because Emily's speaking as a business owner, Katie's coming in somewhere between. I'm the educator clinician.

Jeanette Benigas:

So let me put some of what was said into how does this apply to me as a clinician. And I think this is where my story very briefly will demonstrate that. And this was 2014, so even ten years prior to their audits, the SNF I was working for had an audit from one or two years prior, so twenty twelve or thirteen. My documentation for the course of the therapy I had given was fine. That is not what they ended up having an issue with when the chart was audited.

Jeanette Benigas:

What had happened was the days of RUG where you could get different scores and reimbursement based on the minutes patients got, and so I was discharging a patient who had met goals. And that is what my documentation said. I demonstrated everything, the goals were met, and the therapy manager came to me and said, Can you keep this patient on one more week so we can bump the rub score? And sure, why not? We can work on generalization.

Jeanette Benigas:

What I didn't do, and this was on me, but never had to do that before, I should have updated the goals. I should have added a goal for generalization. But also, I don't even know if that would have helped because the documentation leading up to that was like goals met, discharge next session. By the time they asked me this, I had already put in the discharge. They went in and deleted it.

Jeanette Benigas:

And then we extended the plan of care. So that wasn't really on me either because I wasn't going to be going back and revising previous notes. So that's a little gray. But anyway, kept the patient on for three more sessions. Two years later, the chart gets audited, and the company comes to me, and now it's my fault.

Jeanette Benigas:

Because we're never going to say that the manager asked me to keep treating to make more money. It's my responsibility to have reflected in my notes why that patient needed another week of therapy, and the notes didn't justify that and the money did get recalled and they did have to send it back to Medicare because my notes didn't reflect a need for service. Rightfully so. The patient needed discharge, the company got caught, and I was the middleman. Now, when stuff like that happens, your company is never going to protect you.

Jeanette Benigas:

You are always going to be the first one that gets thrown under the bus. I didn't get written up, but I did get a letter, probably what we would call a PIP today, a performance improvement plan. I had to write to them and document a plan on how I was going to do better so this didn't happen again. This is my favorite. They didn't know I was hired for my first full time academic job from Columbus, Ohio all the way to Philadelphia and that I was moving forty five days later.

Jeanette Benigas:

So I just put in my notice. I said my plan is to not work for you anymore and I'm out. So, I wrote what happened. I said my manager, this is what happened. This was, you know, I rightfully discharged.

Jeanette Benigas:

That was deleted. My plan is I can't work for an unethical company. Peace. Goodbye. So, yeah, we can't all do that, right?

Jeanette Benigas:

But a way to avoid it is to make sure you're doing the things that we're talking about. Because yes, it is your employer's responsibility to make sure that they're following procedures and billing codes and standards. They shouldn't be encouraging you to do anything unethical with the minutes that you're billing or how you're documenting. Or Katie and I talked about up coding. So which is really, well, didn't you really?

Jeanette Benigas:

I've heard this before, where in a lot of skilled nursing facilities, we bill, really, we're just doing that hour eval, but they don't get paid for that. There was a point in time where the company I was working for wanted me to bill fifteen to twenty minutes for an eval and the rest onto treatment. And when I spoke up, I was like, no, I was doing an eval that takes at least forty five minutes. That's upcoding. And the manager literally said to me, well, weren't you like doing some things to like queue them along and like pulling?

Jeanette Benigas:

No, this was an eval. You don't queue during an eval. So that's an example of that upcoding. And so if you get caught doing that, even if your management or your director or whoever has prompted you to do that, you're the one that's going to pay. Now, are they going to take money back from your paycheck?

Jeanette Benigas:

No. If you're PRN, are they going to keep using you? Like, if this was something that happened across many charts and they lost a lot of money? Or are you losing a job? Because I would say that's not wrongful termination.

Jeanette Benigas:

It depends on what state you're in. But if you haven't been billing, coding, and documenting accurately across many patients and they lose tons of money over that, are they keeping you on their staff? You're out because you're the problem, not them. So this is why I'm not putting the onus just on clinicians. But to those of you who need the job, this is why you have to do it accurately.

Jeanette Benigas:

And I would say then if you are let go, you do have a wrongful termination case if you have done everything correctly. And they let you go because they lost money from whatever. So that's just my 2¢. But this is why we need to care. All of us need to care about doing a better job.

Katie Brown:

I'm just thinking about the horror just from being in skilled nursing, I'm having flashbacks of me literally walking out the door pregnant and my director of rehab running after me and going, Are you sure you only saw Mr. Smith for twenty five minutes? And I'm out the door and I'm like, I'm sure that I saw Mr. Smith for only twenty five minutes and then a complete huff and fine, I'll have PT go and see him for five more minutes.

Jeanette Benigas:

Cool. Go for it.

Katie Brown:

Yeah. This happens to everyone. Unfortunately, like this is just a sad reality of this is absolutely what happens. And now it's even more paramount at this point to document, justify, know what you're coding, know what billing, you know? And stick to your guns.

Jeanette Benigas:

Yeah. Emily, anything else before we wrap up?

Emily Watkins:

Back to what I was saying earlier, how we are gonna have to shift, it's really every minute counts now versus it's just a long session. And so as speech therapists, we're not used to that. I know in SNFs and different environments, that does matter. There's minutes counted in different things, but in outpatient and pediatrics in general, it's not a thing. And so if you're a pediatric pediatric and you're listening to this, whether you're an employee, you're a manager, you're an owner, I think it's super important to understand that minutes are now gonna count just like they do in OT and PT.

Emily Watkins:

There's a big range that this could go. You could have the speech therapist that get into the weeds and literally have a timer on your desk. That's not necessary. And then you have some that are just gonna just, oh, I think I did this for about this and I mean, just gonna code at this. I'm not even gonna worry about this part.

Emily Watkins:

And so there's this massive spectrum that that is going to happen. And I think the best thing to do is to not get caught in either one of those and just try to be as realistic as you can. And the best way to do that is to read the rules and know what you're supposed to do. Know the rules from CMS. They're going to come out in November.

Emily Watkins:

They're gonna have the codes. They're gonna have the rules. They're gonna have everything. They're gonna have your NCCI edits if they have any. Let's just cross our fingers if there's not, and if there's no MPPR, I think there's gonna be.

Emily Watkins:

We can get into that another day, but I think it's super important to just know what you're supposed to bill. And at the end of the day, what we tell our therapist is do what you bill, bill what you do. Do what you document, document what you do. And if you do that, 9.9 out of 10, you will be fine. And that is the one thing I would like to leave people with is don't get into the weeds to where you miss a big part of the documentation that could get you in trouble and just do what you bill, bill what you do.

Emily Watkins:

If you do that, you will be fine. And then just get it to a standard. Get it to a very consistent standard at your company or if you're say you're a therapist and your company doesn't care about how you document or they haven't told you anything, then you as a therapist be super consistent and say, this is how I'm gonna do it and be intentional about it and know what you're doing. And so those are the things, just get educated, stay involved because know our integrated service doesn't fit neatly into these sixteen minute, which is why we fought it, is why we made the comments. No, we didn't win that.

Emily Watkins:

I think it was a long shot anyway, but I I think it united our profession, I love, and connected people that didn't know each other before. But I do think it is super important to just those two things is to not get into the weeds of it, but then also take it serious too. And I think just get educated. Go right down the middle. Unfortunately, I wish we could just do therapy and bill it out and they would believe us that we did it, but that's not our reality.

Emily Watkins:

We have to justify why we deserve to get paid what we're getting paid. And then hopefully, there will be some data collection that will allow us to, over time, increase this instead of it going down. So that's kind of my end all takeaway is that every minute matters now.

Jeanette Benigas:

Yeah, thank you. So just looking ahead, it's not scheduled yet, but I still might have a bonus or a mini session about schools. I have to get that scheduled. Emily and I are working on this larger project. We're working towards a consultant or a lobbyist.

Jeanette Benigas:

I've started calling it a dream team. I looked at AI last night and I was like, Here's my plan. Who do I really need? And AI was like, Well, if I had a budget of 2 and 50,000 to $500,000 then I was like, Stop. This is PhDSLP.

Jeanette Benigas:

I've got like $5,000 we're working on that sometime soon. So, we'll get an episode on that. We've got some school things coming up. And then who knows what's next? So, you may not have an episode next week, one week from when this drops.

Jeanette Benigas:

It will depend on if I can get that school's episode scheduled and if Emily and I can get nailed down what we're doing. The one more thing that Katie and I I messaged her last night, which is, I can't believe we forgot it because Katie and I met over collaborating on telepractice, but we didn't mention that none of these codes are included for telepractice for SLPs. So we just fought that fight, and now we need to fight it again. So whatever Emily and I do in terms of the lobbyist for CMS or the consultant, it will include comments like that. Obviously, we all know why that's important.

Jeanette Benigas:

I don't think we need to rehash it, but just be aware that we forgot to mention it. So, stick with us. We promise guidance for comments are coming. It's coming. We're working on it.

Jeanette Benigas:

Ladies, thank you for coming. Katie, you'll have to come back. Let's make it five.

Katie Brown:

Let's make it five.

Jeanette Benigas:

Yeah. So everybody have a great rest of the week and thanks for fixing it. Thanks for listening to the FixSLP 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 PhDSLP team.

Jeanette Benigas:

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 fight at a time.