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CPT 92507 is being deleted and replaced with new time-based speech therapy CPT codes. What does this mean for SLP reimbursement, Medicare billing, work RVUs, and compliance?
In this episode of Fix SLP, Jeanette Benigas, PhD, is joined by Rick Gawenda to break down:
• Why CPT 92507 was targeted for review
• The new proposed speech therapy CPT codes
• RUC work RVU recommendations
• Practice expense implications
• The shift from untimed to timed codes
• The risk to auditory processing disorder and communication in the new code language
• How audits and payer denials could increase
• What SLPs can do before the March 6 open comment period
• The new proposed speech therapy CPT codes
• RUC work RVU recommendations
• Practice expense implications
• The shift from untimed to timed codes
• The risk to auditory processing disorder and communication in the new code language
• How audits and payer denials could increase
• What SLPs can do before the March 6 open comment period
The AMA CPT Editorial Panel approved deleting 92507 and creating ten new time-based treatment codes. But what’s missing? Language that includes auditory processing disorder, communication, and flexibility for real-world therapy sessions.
If you’re a speech-language pathologist in private practice, outpatient therapy, pediatrics, hospital, SNF, or home health, this episode explains exactly what is happening and what could change in 2027. This is the episode every SLP needs to hear about CPT 92507.
You can find Rick Gawenda on Instagram, TikTok, YouTube, Twitter, Linkedin, and Facebook, or at https://gawendaseminars.com.
✨ Grateful for Beaming Health’s partnership in helping clinicians handle insurance so they can focus on patients. Make sure to let them know that Fix SLP sent you! ✨
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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.
Hey everybody. I don't know if you remember our previous partner Verse Therapy, but they recently merged with Beaming Health. I'm really excited to get to partner now with Beaming Health because if the 90 two thousand five hundred seven headache has taught us anything, it's a reminder that the insurance system for SLPs is a mess. So Beaming Health is the insurance partner that's going to help you make this mess a little more simple. Beaming helps SLPs start and grow their private practice by helping with one of the hardest parts.
Jeanette Benigas:It's getting in network and accepting insurance and Beaming takes on that headache so you can focus on care. I know for me one of the hardest parts is dealing with insurance. I hate billing in my private practice. I hate it. And so Beaming is a really good solution to that.
Jeanette Benigas:They're full service. They help SLPs get in network. They offer ongoing billing support plus a payment guarantee that SLPs will get paid on time 100% of the time. Listen, I just had a place call me today and I duplicated an invoice number. How do I even do that?
Jeanette Benigas:I don't know, but I bet Beaming doesn't do it. So if you don't want the headaches that I have or if the idea of messing with insurance is preventing you from starting a practice, just reach out to Beaming. You can check them out at beaminghealth.com. I will have them linked up in the show notes. Their support is so appreciated because it supports the team.
Jeanette Benigas:Enjoy the episode. 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.
Jeanette Benigas:So let's fix SLP. Hey, everybody. Welcome back. It's Jeanette. We have, I think, what's gonna be the podcast of the year.
Jeanette Benigas:I thought it was going be when we brought on our attorney, but I think our guest today is going to beat those numbers. I have Rick Gawendo with us today and before we jump into that, I want to just remind everybody, last week we had Jordan Montique on the podcast who is putting together the free speech directory resource for families and for SLPs to register their services. Go throw her $5 She's funding this thing thousands of bucks out of pocket and I would love the first year funded. So, we're not going to waste any time. We're going to jump right into this.
Jeanette Benigas:So, I have Rick Gawenda with us today. I'm going to let him introduce himself because I just found out who he was a week or two or three ago. But all of you have been screaming his name for a while. So thanks for coming on with us. Rick, you want to tell us about yourself?
Rick Gawenda:Yeah, thanks, Jeanette. Thanks for having me. And I'm not sure it's it's a good thing I'm going to beat the attorney in terms of not a good thing. But I know why this is going to be an important podcast. So for those of you that do not know me, my name is Rick Gawanda.
Rick Gawenda:I am a physical therapist education and I'll say I'm going to be one of those old PTs, meaning I graduate back in 1991 with a Bachelor's of Science degree in PT as PT moved on to Master's, then doctorate kind of grew up in the hospital system as a staff therapist, eventually into hospital administration. I did that until December 2009. Started my company, but one of seminars and consulting back in 2003. So for twenty three years now have focused a lot on the outpatient PT, OT, SLP side in terms of compliance documentation, CPT coding, productivity, revenue enhancement, things like that. I'm also retained by attorneys when unfortunately therapists and assistants can begin to do some trouble with a state licensing board or insurance company and retained as an expert, usually on the behalf of the therapist or assistant.
Rick Gawenda:And finally, my wife and I and another business partner also owned a couple of private practices here in Southern California for seventeen years. We did sell those about four years ago. So I've got a pretty good background on the private practice side, as well as a hospital side and then of course, being the consultant for twenty three years.
Jeanette Benigas:So we have the voice you guys, he's here. It's not me, it's him. Just to be upfront, I think at this point, everybody knows this. I have signed the confidentiality agreement with the AMA, so I have to still be careful what I am allowed to say. However, I did confirm some things that I heard back this morning just in time that I can say while we're chatting today.
Jeanette Benigas:Rick, his is more regarding the issue that has already passed and with the RUC values being published, and we'll talk about all of that. Rick feels like he can say a little more than I can, so I'll be asking a lot of questions and he'll be doing a lot of the sharing. And especially since I've been interacting with so many of you online over the past few weeks, I think I have the pulse on what everybody wants to know. So Rick, do we want to jump into ninety two thousand five hundred seven? How the heck did we get here?
Jeanette Benigas:For the people who haven't heard about it yet, What do they need to know?
Rick Gawenda:Yeah, and as you just alluded to, think it's great timing because the recommendations for the new codes did come out on February 19. And now because, quote, the public, everybody can now know what the new proposed codes are, the values of them, the descriptors, etcetera. That kind of takes my NDA away, which is great timing for today's podcast. So ninety two thousand five hundred and seven, obviously, as myself, you all know, it really encompassed everything you did treatment wise as a focus on language, voice communication, auditory process and disorder. Well, what's what CMS looks like?
Rick Gawenda:And I know I'll say that people listening that do adults and geriatrics and then I've got SLPs that do pediatrics. And if you're a pediatric SLP, I know you don't do Medicare, but you actually do care what Medicare does. You know, Medicare is looking at the utilization of CPT codes. So 92,507 in 2017 was billed just over 200 around $232,140,000 units to the Medicare program. In 2024, it was billed for just under 820,000 units.
Rick Gawenda:Now keep in mind, when I say these units are billed, it's only outpatient therapy, because in a sniff party setting, reimbursed via CPT codes are paid via PD PM hospital acute care. It's DRG hospital and patient rehab different payment system. So when we talk about the number of units billed to the Medicare program, this is just outpatient therapy. Well, because of the quote, tremendous growth over seven years in of 09/25/2007, it kind of triggered CMS to do a review of that code. So they reached out to a few of the specialty societies, of course, one being, you know, yours, so to speak, to look into the 92507 and should some changes be recommended.
Jeanette Benigas:Somebody must have put something online in the last twenty four hours because I've gotten seven messages already about it today. One thing that I keep being asked that I've answered but I think a lot of people want to know is did the increased utilization happen because of ABA therapy? Are ABA therapists billing 92,507? Do you know that answer? I do.
Rick Gawenda:Yeah. And again, we don't know the answer, of course, on the CMS side because typically, you know, CMS for ABA therapy doesn't really exist. There are ABA CPT codes 97151 through 97158. Now my opinion only, does it make sense from 2017 to 2024 to see it go from 240,000 to just shy of 820,000? I mean, you expect to see an increase because no offense, we're all getting older.
Rick Gawenda:You know, people are living longer. You know, with COVID, Did that maybe increase the use of speech because of telehealth now coming about or somebody if they could only maybe come one time a week physically to an SLP or not because we've had telehealth available to us since April slash May 2020? Are we seeing some extra business being done there in the Medicare population?
Jeanette Benigas:Or even just access to areas we didn't have access to before. And just having COVID, I am a medical SLP. So seeing people after COVID who maybe haven't been intubated and now have voice issues, there were a lot of issues. But if you didn't hear Rick say it, I'm going to say it again. We have someone on our little team who's anonymous right now who has ABA as part of their large practice.
Jeanette Benigas:The ABA typically is not billing 92,507, and these numbers didn't include pediatrics at all. So it wouldn't really have included ABA. So we're squashing that now. That also accounts for music therapy. I've seen that one too.
Jeanette Benigas:We are less certain on that because none of us have music therapy in our practices. But from what we can tell online, music therapists are not billing 92,507. So that could be wrong, but we're pretty sure based on our research, again, that doesn't account for the overutilization.
Rick Gawenda:Well, we know in the Medicare program that music therapists are not a qualified provider of services that would be reimbursed by the Medicare program. So we feel pretty confident that the numbers that CMS is putting up publicly, so those numbers I'm giving you, they're public. You know, I can always share the file or the link and you can put that out if you want to read about, you know, the number of units of every CPT code billed every year under the fee schedule that is available publicly. Typically, it's about a year or so delayed. So September, CMS will release the 2025 data.
Jeanette Benigas:Okay, yeah, we'll take it. I'll connect with you after. And for anybody, for all of these resources that we're going to talk about, I don't even know where we're going, so I don't even know what resources we're going to say yet. I will create a tab on the Fix SLP website that will be in the main menu. I'll make it so you don't even have to search for it.
Jeanette Benigas:I'll bump it first for a little while and I'll just have it so it's right there for you. And every one of my posts where it says comment a special word to get a link to somewhere, I'll make sure all of those links are there as well. So it's all organized in one place for everybody to go, and that'll make it nice and easy. So that's kind of how we got here. So somebody put forward a proposal back in what, August?
Jeanette Benigas:It was August that that proposal went forward, August 2025?
Rick Gawenda:Well, the proposal would have been submitted prior to the August because that's when the agenda was published. So I know I'm going to give a quick overview there, and I know you provide a timeline of what you were saying. Yeah. But basically, the meeting occurred in September. I think it was September 24 to the 2025.
Rick Gawenda:So this is the AMA CPT editorial panel that considers proposals to add new codes, delete current codes and or revise current codes. What the agenda for that meeting came out about seven weeks before sometime in early August. And that's the first time like I myself saw that somebody had submitted a proposal to recommend the deletion of 92507, the addition of 10 new CPT codes, plus the revision of your group therapy code 92508. And that came out sometime in early August. Obviously, the proposal to do all this had to be submitted, you know, in advance of that meeting.
Jeanette Benigas:So this wasn't something that just popped up. This was years of research and planning, we're assuming primarily by the American Speech Language and Hearing Association. But this is a de identified for the most part, a de identified process. But they were contacted. They were involved in making recommendations.
Jeanette Benigas:We were flagged in, I think we said April 2024. And I have the date here. The agenda was published on 07/11/2025, it looks like. So that is when the meeting agenda was published online. It included 92,507 in the agenda to discuss deleting it.
Jeanette Benigas:07/11/2025 was when it was published, and that is also when the interested party portal opened for people to make comments, meaning any stakeholder. And by the way, I've looked into it. There's no definition of what a stakeholder is by the AMAs. I would assume you have to be 18 or older, but I didn't even read that. If you feel that you're a stakeholder, you can go sign up to be an interested party on the AMA platform.
Jeanette Benigas:And when you do that, you get a packet that includes the proposal and any supportive documentation that's going to be reviewed by what's called the editorial panel. And the editorial panel is a group of 200 doctors and health care professionals. I did ask during a meeting with the AMA. No one on ASHA holds a seat on that panel. But those are the folks who look at all of these proposals.
Jeanette Benigas:They have to read all of the comments that come in through the open comment portal during the window, and then there's a meeting for discussion and then they vote. So you can submit. Those are the people that need to hear comments when something's being considered. So that window closed on 07/25/2025. On August 7, the American Speech Language and Hearing Association made a statement on their website that there had been some, what they love to call, social media chatter.
Jeanette Benigas:They said there's been conversation on social media. People are concerned about 92,507. We are here to assure you that we're aware. We're monitoring the process. Nothing is changing now or anytime soon.
Jeanette Benigas:And basically, we'll let you know when it's time to change how you bill. That was it. Now, here's the problem. That open comment period was extended to August 12. So in the middle of this open period where this proposal had been submitted, that impacts every single one of us in the field, whether we're adult or NICU, whether we're private pay or we bill insurance, at the end of the day, the entire structure of how we operate was on the table for change and they didn't tell us about it.
Jeanette Benigas:That's it. Whether you like them, love them, hate them, whatever, those are the facts, ma'am. They're that's they didn't tell us about it. It was open, and they didn't tell us about the upcoming meeting, which Rick, we said, what were the three dates of the editorial panel meeting then?
Rick Gawenda:I think September, I believe.
Jeanette Benigas:Yeah. Don't quote us on that day or two forward or back. It was right about that time. Then that was when the meeting occurred. And that is when the proposers of this proposal, the submission had what three to five minutes, Rick?
Jeanette Benigas:How long do people get to talk?
Rick Gawenda:I mean, it's not like a dead set time, but I listened to that portion of it and it went pretty quick.
Jeanette Benigas:Okay. Well, better they better give me twenty minutes because I'm long winded. Sometimes pastor John, who was my dad, he was a pastor, sometimes pastor John comes out and I get going and I don't stop. So I am allowed to say at this point because we'll talk about this later. The AMA did give me permission to say that I have played a role in submitting a new proposal.
Jeanette Benigas:So yes, the people who submitted the proposal go to this open meeting that again anyone can attend. Anyone can go online, register to view it, And from what I understand, Rick can also go in person. Correct?
Rick Gawenda:Correct. And in person, quote sells out.
Jeanette Benigas:Okay.
Rick Gawenda:So when opens up, if you really do want to attend in person, you really have to sign up quick.
Jeanette Benigas:Okay.
Rick Gawenda:That the space is limited. I've always done it virtually.
Jeanette Benigas:Okay,
Rick Gawenda:because the cost of course to fly to wherever it is. Right. And I would get into what's coming up here at the April where that location right coming up. But yeah, and to say that packet, you know, I downloaded that packet on July 25. So that's when I download it and that packet was 118 pages and that 118 pages.
Rick Gawenda:It's all on the new codes. So that 180 pages is a package just for what Jeanette and I are talking about here today.
Jeanette Benigas:Yes. And I have seen that packet. People have asked, well, how did you get to see the packet when this is all over? Why didn't I? And that is because when all of this came to light and we'll get to that, I was asked to partner with these private practice owners.
Jeanette Benigas:So we'll get to that. So the open comment period was extended to August 12. Then the meeting in September happened. The editorial panel voted. The decision came out approximately, I think, two weeks later.
Jeanette Benigas:Then on January 28, ASHA published an article entitled Update on CPT code ninety two thousand five hundred seven valuation review underway. So they put that on their website. So they were there. They knew it happened. They knew it was happening the whole time.
Jeanette Benigas:Didn't signal SLPs about the comment period, which they were allowed to do. It is within our right as application submitters to say to people, it's our understanding. And I wrote this down because I wouldn't sign I wouldn't sign the agreement until I knew what I was allowed to say. I said, tell me exactly what I'm allowed to say. I am allowed to say, I have become aware that information has been published to the American Medical Association website regarding ninety two thousand five hundred seven.
Jeanette Benigas:If you're interested in having your voice heard or checking out the information, click this link here. Same agreement for confidentiality. Same process. They didn't say that. So that's unfortunate.
Jeanette Benigas:So it went through. It was passed. So now people start hearing about this. People then get a survey. Do we know when the survey went out, Rick?
Jeanette Benigas:It was in October.
Rick Gawenda:Yes. So again, as you said, the CPT editorial panel, you know, the changes to the SLP codes late September twenty twenty five. Typically, about two to three weeks later, the minutes of that meeting is released. That's when any one of you, you know, publicly could have seen the code that was approved, that 9507 was approved for deletion. These 10 new codes were approved to be added effective January 2027, and the group code to be revised.
Rick Gawenda:After that, a couple of weeks later, AMA slash ASHA, they sent out a survey to a certain number of random members of ASHA. And the survey went out to, know I gave you the number the other day, I think about what, 9,400, 9,800 members?
Jeanette Benigas:It went out to 9,041 people. And their website does define member. It is my understanding that they're supposed to try or give their best effort to reach all SLPs. So not every SLP is a member of the American Speech Language and Hearing Association. Some just purchase the CCC product.
Jeanette Benigas:Others choose not to purchase either. And when they define member on our on their website, that means they only sent these to people who pay them for membership and the product. And that's slightly problematic. But that's what they say. It went to 9,041 ASHA members.
Rick Gawenda:Correct. And then this survey is when those members, if they would have opened it, would have seen, hey, you know, they got some new codes being proposed, etc. Because the survey is trying to get information from those members about time involved, equipment involved, etc. I mean, it's a very complicated survey. I'm not sure if you've had a chance to see it or not, Jeanette, but when remote therapeutic monitoring codes came out, I could, I saw that survey.
Rick Gawenda:And this is kind of what I do for a living. I had a hard time giving input on the RTM stuff. And this is what I do for a living and know this stuff. So I can't imagine how it could be for some of the SLPs who are not understanding all the equipment that goes into it, that maybe a support staff time, But I'll say it now and sure we'll talk about again later. Over 9,000 surveys that went out, they got less than 1% back.
Jeanette Benigas:And yeah, approximately point 73%. Now, I'm a Ph. D, so I know the original number I was hearing was 500. So I ran that number against the 240,000 people ASHA says they have. And truly that response rate, while it seems small, statistically speaking would have been okay.
Jeanette Benigas:It wasn't as much as the number as it is the spread. Do we have an accurate spread across the nation and placement or location where people work? I haven't run the statistics on this number, but I don't know how appropriate it is. But that's where we're at.
Rick Gawenda:Per the 10 new CPT codes, responses vary from anywhere from about 53 responses on one code to maybe 83, 84 and another code. But I do agree we don't know where those 53 to 83 came from, because what if they're all in the Northeast and we left out Texas or Florida or about, you know, Alaska, Hawaii, where things are different in terms of costs.
Jeanette Benigas:And and we do a lot of studying of the American Speech Language and Hearing Association on this platform. There's a lot of the issues we have just go directly to there. You've heard this from us before that ASHA is largely controlled by people in academia with PhDs. I, having been one of them for our new listeners, I worked in academia for ten years, left as a full professor, highest promotion you can get. I understand the mindset and the mentality and the process.
Jeanette Benigas:Those are typically the people most engaged in ASHA. So I would be very interested in seeing how many productivity driven clinicians responded to this survey who have very busy days and lives versus PhDs who sit on campuses all day in offices and are literally paid to read research and keep up with the profession. My guess is that this is very heavy and this is just my opinion, very heavy PhD academic response and very light productivity driven clinician response. And there's a big gap between those areas. As I've said, I own my own practice.
Jeanette Benigas:I have practiced for nineteen and a half years, even in those ten when I was in academia. And those are two very different mindsets and the people on the academic side don't always understand the clinical side. There are some that do like I was one of them. But largely, people in academia don't treat patients, they don't bill like we do and they don't understand the repercussions of maybe what they were reporting. So something to consider.
Rick Gawenda:I'm sorry, I had one thing, they don't understand the business side either. No. No. That. I mean obviously I know the AMA does not care about reimbursement.
Rick Gawenda:I know the vast majority of your listeners do care about reimbursement. Right. And I know you and I would get into that eventually what the AMA cares about, the RUC cares about and how that may not always agree with what we care about.
Jeanette Benigas:And I know I probably have a lot of new followers in the last few weeks and certainly a lot of new listeners today, but I can tell you the one thing that my I call them we all call ourselves Fearless Fixers because we fix things without fear. The one thing that Fearless Fixers care about is their money. When I post about money on my platform, those posts are the ones that go viral. If if I wanted to be viral every day, I could just post about money, but I reserve it for when I really have something that needs to be said. But I know when I post about money, people are watching, and this directly relates to our money at the end of the day.
Jeanette Benigas:But yes, the AMA doesn't care about that. So we can talk about that. So this survey went out. We have questions about the amount of responses. I've seen people who maybe have been part of this process on social media say, well, this is in line with every survey that the AMA gets back.
Jeanette Benigas:I don't know about that. Do you have any information about that, Rick? Is this small amount of responses, would that be in line with other proposals that you've seen the AMA consider?
Rick Gawenda:Doctor. Yes. Okay. And again, I know we're going to put the link out where people can go read recommendations that we're going to eventually talked about here. And you can kind of go and see the other proposed codes that the RUC looked at and you know, see the surveys and that and I could tell you from the PT side, you know, we tend to get a very low response.
Rick Gawenda:And we saw that with RTM was the latest ones, because we had new RTM codes come out this year that we surveyed back in October, November 24. And again, very low turnout.
Jeanette Benigas:Let me ask a question, though. How many members does APTA have? Do you know?
Rick Gawenda:I know it's over 100,000. I don't know the exact numbers anymore. Know it's still over 100,000.
Jeanette Benigas:And membership retention is around 20% based on the research I've put out over the last couple of years. It's probably up or down, but somewhere in there. I just want to point out that ASHA touts, you know, over 240, so more than double what the APTA has. And we know that's changing. I put out a post today showing the 117% decrease or something since Fix SLP came out.
Jeanette Benigas:But with double more than double the people, we should have seen a higher a higher rate. Right? They've they've won awards before Fix SLP was around. They were winning awards for 98% retention rate. That's a podcast.
Jeanette Benigas:Well, we've done those podcasts. We've had many of those podcasts. But with 98% of the profession retained, we really should have seen more responses. And, you know, maybe that was a result of less than 10,000 being sent out. I don't know.
Jeanette Benigas:All assumption. So these surveys were sent out and that's when. Things started to get a little crazy, so we had ASHA in November, November, there was a clinician in one of the ASHA led sessions for CEUs on what to expect for billing coming up in '26, and this topic didn't come up. So one of the people who received the survey raised her hand and said, Hey, can we talk about this? And I've spoken to her directly.
Jeanette Benigas:So this is coming out of her mouth to through me to you. She was shut down. You signed in, you signed an NDA, you're not allowed to talk about that. We can't talk about that. And she was left wondering what just happened here because I didn't sign a confidentiality agreement.
Jeanette Benigas:I didn't sign an NDA. You all sent me this survey with the new codes in it. And I want to know about this because it's been passed. And the folks leading this session, from what I understand, were all members of the health care economics committee that would have if they were the ones who put the proposal forward, They would have been under the confidentiality agreement, but certainly could have said some things. Also, we know some of them, their names are all over this 3,000 page document that you can get on my website.
Jeanette Benigas:So they shut her down And then afterwards, a lead SLP from another very large private practice approached her and said, I didn't hear anything about this. Tell me more. And so quietly and collectively, some private practices starting started getting together to research what happened, what the implications would be for their business, and started contacting the AMA and people like Rick to figure out what went on and what can we do. So then you had a Growth Code Conference. When?
Jeanette Benigas:When did that happen?
Rick Gawenda:Yeah. So the individual you're speaking about, I'm not going to mention her name. And she asked that question because she's a client of mine. So I I won't say heads up, could only say obviously, was limited in what I could say since they were looking at purchasing a speech therapy practice coming up. So I said, Well, you're going to need to be careful as you're going to maybe look at buying this practice seven and beyond if these new codes go into effect.
Rick Gawenda:So I just could tell her what was you know, been published already. And she understood, you know, the NDA piece of it. And that's what then enabled her to then ask those questions. Well, because of that, and what you just said, kind of the SLP community now coming together, there was a big pediatric growth code conference. It was down in Miami near the January.
Rick Gawenda:So this individual was there as well as as many other SLPs, some of whom had received a survey. So, you know, we could talk at the dinners and all that ahead of time. They would just have to share information with me and then I would go, Really? That's interesting. Yep.
Jeanette Benigas:Kind of like we're doing today, right?
Rick Gawenda:A lot more today now.
Jeanette Benigas:Right, right, right.
Rick Gawenda:So then they kind of understood that process of what they had gathered and, you know, obviously seeing the survey, they knew what was coming. So then they were able to get up as I was doing this session on speech therapy coding and billing a growth code and kind of here's what's here's what I can tell you. Here's what's been approved. Here's where it stands now. And then these other two SLPs were able to stand up and communicate things that they could share because we're not under an NDA.
Rick Gawenda:And that by that time, when this meeting had occurred, the RUC committee, the AMA RUC committee had met 01/14/1516 in California. And this is the RUC committee. Then it determines the relative value units for these new codes, the work RVUs and the practice expense RVUs that we're going to talk about later as well.
Jeanette Benigas:By the time all of this was happening, these codes had already been decided, right? The valuation process was pretty much done. And those recommendations are what we're going to talk about. So as these practice owners pushed forward with the AMA, they were able to get some meetings. The AMA advised them on what they needed to do, which was submit a second proposal that would revert everything back to the table for revision.
Jeanette Benigas:And I want to make that clear that and now that I am allowed to say that, that that is the goal, that the proposal would, from where we are today, it would put everything back to the table to be revised. Maybe we don't have these codes. Maybe we do. Maybe there's KX modifiers to change inpatient versus health care versus peds with the goal of having the correct voices and stakeholders at the table probably is going to include ASHA, but there needs to be additional people at this table. So I was then approached, I feel like at the February, to be the voice of this because I have the platform.
Jeanette Benigas:And when they proposed it, they said you can think about it. We know you might want to get involved. And I said, you kidding? This is why I created this platform. I created this platform as a place, a conduit for advocacy for the whole profession outside of the American Speech Language and Hearing Association.
Jeanette Benigas:We have T shirts that literally say we don't wait for change, we make it. Early on in one of my previous accounts met SLP advocate, I would say if ASHA won't do it fine, we will, right? That's what we're here for. Yes, I am going to help you do this. And I know the people and they said we want this to be viral.
Jeanette Benigas:And I said I know how to do that. This is my chance to shine. So very, very quickly, I notified all of you with the yellow 92,507 post, which is reaching just from the original post 260,000 views. That doesn't count all of the other statistics. Guys, we went viral like outside of niche SLP viral.
Jeanette Benigas:Okay, that's what it did. And then they started to meet Jeanette Benegas. Okay, they started to learn who she was. Oh, has academic writing experience. Oh, she knows how to research and pull.
Jeanette Benigas:We need research for this proposal. She knows how to do that way quicker than we do. Oh, she knows how to interpret it. And so it became very obvious at that point that aside from being the voice, I also needed to play a role in writing the application. And so I played a role in that.
Jeanette Benigas:I didn't do it alone. There were three of us primarily who did that, different sections. And then we submitted that. And there is an approval process that it has to go through. And we're in the middle of that now.
Jeanette Benigas:But I can safely say that the AMA is already telling all of you something has been submitted and you can make your voice heard on March 6. So we haven't gotten notice that it's been approved yet. I don't know if I'm even allowed to say that, but they're telling you you'll be able to make your voice heard through the interested party portal on March 6. I believe the deadline then will be March 31. It is important to know that once you go in and do that and read our packet, you will also sign that confidentiality agreement.
Jeanette Benigas:So if you want to educate or spread information or help people along in this process, you should probably wait until the end because once you sign it, you can't go online and talk about it. You'll have to be a little more careful. It's important and we're going to get into this too, I think here pretty quickly. It is important that you speak to the proposal that our little team has put forward and not to all of the noise we see on social media. Rick and I have some opinions about that, which he's he's going to bring some of that to light here in a few minutes.
Jeanette Benigas:Our team is in complete alignment with his opinions. So these are our voices right now are the ones you have to maybe trust and listen to. Over the next couple weeks up until March 5, I'm going to be putting out a lot of education material, carousel slides to read on Instagram and Facebook. Then as soon as Rick and I get off, I'm going to be recording voiceovers for the ones I've already done. And I have a helper who's going to be getting these on YouTube so you can stream them in the car, hear what I say, I'm going to try to make them short.
Jeanette Benigas:Know I tried to do an Instagram live for five minutes and it ended up 30 the other night. So, you know, we're going to try to keep it tight. Okay. But that way you all can be ready to make an intelligent, well thought out response. And you don't have to agree with us.
Jeanette Benigas:That's the thing. I might be teaching you how to write an intelligent, well thought out response to oppose what we've submitted. And that's okay. I can't sway you either way. I want to make sure that your voice is heard in the appropriate way so the panel doesn't read your thing and just put it in the trash bin.
Jeanette Benigas:You're going to take the time as a busy business owner or clinician to sit down and write something well thought out. You want it to be read and understood and considered. And then the other thing is a lot of our Fearless Fixers have been involved in state level advocacy. Fix SLP has given you some templates or some talking points on what to say, And then you go to the open public open comment period and you write what you think and everybody gets to read it. This is a de identified process.
Jeanette Benigas:So when you get the packet, you're not going to see my name, it's de identified. When you submit your comment, the only people who will read it is our little team of submitters and the editorial panel. And your name, I believe, is de identified. So you don't get to know who we are. We don't get to know who you are.
Jeanette Benigas:And that's part of that confidentiality agreement to protect all parties. So one person isn't swaying another person because you know, y'all know if we read ashes, we're gonna blow that up, right? So everybody's protected here. Nobody's getting mad at anybody else, but that way you can truly have your voice heard and there's no outside influence. And then that keeps it fair for the editorial panel.
Jeanette Benigas:So while a lot of us, including myself, have some gripes about this being a confidential process, that is one good thing is that they try to keep the noise out of it and really get down to what matters and that is the proposal that's in front of you. April 30 through May 2 is the CPT Editorial Panel Meeting. I will be one of, I think, two people speaking there on behalf of what was put forward by our little team. You can register to watch online. Rick said, if you wanna go to Boston, I'm thinking of having a little Fix SLP meetup, not like we did before where I have tickets, but maybe a coffee shop or something.
Jeanette Benigas:If you want to go to Boston and be there, Rick said, you have to do that pretty quickly and pretty early. But that's available where you can hear what we have to say about what was submitted. But also what I think is significant is anybody can ask a question. I've testified in the Michigan House of Representatives on a bill that I have going through there with Michigan SLPs. You had to submit your questions on a card.
Jeanette Benigas:Is that how that works, Rick? Does your question get pre submitted and then they choose? Do you know how that happens? That process?
Rick Gawenda:Doctor. In person, I do not know. When I do virtual, I just raise my hand in the virtual thing. And when they say my name, I can then ask my question and or make my comments. I'm not sure how it works in person.
Jeanette Benigas:Okay, so they're not even screening you out. That's good. So you yeah, you can get your questions answered. Hopefully we know. Hopefully I know the answer.
Jeanette Benigas:But then after that, then they vote and the summary is scheduled to be posted on May 15. That is the whole timeline of where we've been, where we're at now, and where we're headed. We're going to take a quick break here. We support our back end expenses with sustaining partnerships, but we don't pay the team for their work. It's all been volunteer.
Jeanette Benigas:It takes me four to ten hours a week to get a podcast from Concept to your ears, and this week the episode was double the time. So I am so thankful these folks partnered with us to support us in getting this ninety two thousand five 107 message out to you because our partners help pay the team. So don't forget, go check them out at beaminghealth.com. They're also linked up in the show notes for you to check out. Enjoy the rest of the episode.
Jeanette Benigas:Doctor.
Rick Gawenda:The one thing I would say about the agenda, if you are there in person, or you are listening, you know, live virtually, you'll know what happens right away. You're going to know the outcome and all that. You just can't say the outcome to anybody that you know, because again, you've got that confidentiality agreement, you have to wait for the meeting minutes to be posted, which I think you said they're expected on March 5. I'm sorry, May.
Jeanette Benigas:Yeah, May 15. Rick, I like to find loopholes. If I just put a green square on my content, does that count? Is that how I signal to my people that we won or is that will I get in trouble?
Rick Gawenda:Well, that I
Jeanette Benigas:Do we know that answer?
Rick Gawenda:I wanna do that with my eyes on.
Jeanette Benigas:I listen. Ask for forgiveness, not permission. Right?
Rick Gawenda:You're gonna be there. So yeah. And again, if you win, and when I say win, you know, we get the outcome that we want and all that, whatever that may be. I can't, you know, put right. You may want to ask AMA, you know, are you allowed to post this anywhere or do you have to actually wait for the media minutes to come out before you can say things have changed?
Jeanette Benigas:Yeah. So
Rick Gawenda:but I do want to stress what you've already said, the confidentiality piece, you know, March 6, if you are going to go out there, you're sign up to attend live and or virtually, and you didn't have to sign up your work, you can just download the interested party and download that packet, however many pages that may be. But to do that packet, you are agreeing not to share the information, etc. And I can't stress how important that is. You know, I know people say this, you know, people thought I was hiding things back in September, October, November, and that I wasn't being forthcoming. I can't.
Rick Gawenda:This is, you know, this is what I do for a living in these meetings all the time. So you have to take these confidentiality agreements seriously and not screw up the process.
Jeanette Benigas:Right. Right. The last thing we want are sanctions, right? That we're we're doing everything we can to get voices heard. So we really do want to protect this process.
Jeanette Benigas:I don't think I've had so much little sleep since my kids were born. So this is like a third baby now. I had a dissertation, two kids, and now the AMA application. So yeah, we want this to be worth something. And you know what, maybe SLPs don't want what we put forward.
Jeanette Benigas:And that's okay, too. At least they got their voices heard. And that's the point of all of this is Fix SLP wants clinicians to get their autonomy back. And this is an opportunity for you to have some autonomy in the decision making process. If you don't like what was done, that will be the time to say so.
Jeanette Benigas:Well, within the confines of the application. But if you do like it and you don't like what was put forward, you have every right to say that again, in an educated way that will be considered.
Rick Gawenda:Yeah. Yeah. And again, I can just give you my opinion and obviously what's already been approved. You know, obviously, I think leaving out the words, alterative processing disorder is a big issue, because that does not appear any of the five codes have been approved. And then of course, you've got the word communication.
Rick Gawenda:And again, I'm not an SLP, but I hear SLPs say we have to have that word communication. This is a big one we're missing. And I have other SLPs saying, well, communication is inherent in speech sound production. Communication is inherent in voice. It's inherent in language comprehension expression.
Rick Gawenda:I think it was what you just said. They're going to be people that are going to many, my opinion, many SLPs are going to speak against what got passed originally. But there's gonna be, I think, some SLPs that are gonna be, you know, this is what they want. And again, I can't say neither side is wrong or right. It's just what do you believe and what do you support?
Jeanette Benigas:I don't want to glaze over what Rick just said. You haven't heard me say it for a reason, but I think I can repeat what he said. He said, auditory processing disorder is missing from the new code set. The word communication in the definitions that go with those codes is missing from the descriptions. Communication and auditory processing are missing from what has been approved.
Jeanette Benigas:And you can go through the 3,000 page RUC packet or the 164. I've got it. It's 160. I've gotten it down to only the SLP pages and you'll be able to get that on my website. Search and find in those documents.
Jeanette Benigas:It's not there. And I think that opens us up for a lot of trouble with audits and a lot of gray area that if we use the word communication, is the money gonna have to be sent back? I think that it can be very problematic. Mhmm. Obviously, we need to treat auditory processing disorder.
Jeanette Benigas:So even if somehow this whole process landed us with a raise, we've limited our scope of practice. And for that reason only, in my opinion, we should be revising this to at least get that back into our scope because we have an entire group of people that we serve that rely on us, speech language pathologists, for that service. And it's not there. That's what Rick said, right? Did I hear you right, Rick?
Jeanette Benigas:That's what you said.
Rick Gawenda:That's what I said. I'm gonna take some of you kind of back to 2013. So in 2013, you had one eval code 92,506. And it was for the evaluation of, you know, voice fluency, communication, speech, auditory processing disorder. That that's what the eval code said.
Rick Gawenda:And then you had 92507 that said the treatment of speech language, voice communication, auditory processing disorder. When 2014, you went from that one eval code to the four codes you really know now, you know, 92521 fluency nine two five two two speech sound production, nine two five two three speech sound production and language comprehension expression, and then nine two five two four voice and resonance. So my opinion from '13 to '14, you lost auditory processing disorder then. You lost the word communication then in the eval codes, and nobody said anything. So now when these new treatment codes came up, really what the specialty societies did include an ash in my opinion, they just took eval codes, turned them into treatment codes because you're going to I know she can't say it, but I can.
Rick Gawenda:There's going to be a treatment code for fluency. There's a treatment code just for speech sound production. There's a treatment code just for language comprehension expression. There's a treatment code for speech sound production and language comprehension expression, and then the treatment code for voice and resonance. So basically, they did is took your 40 vowel codes and turn them into the new five treatment codes.
Rick Gawenda:So really began in my opinion, twenty in twenty fourteen.
Jeanette Benigas:And with that umbrella code of 92,507, there was a lot of room for fraud within that code. This is what we see on the healthcare side. Someone brought it up today, asked it under a post and it's what I see. Somewhere along the way, I don't know what year you might know, Rick, Cognition was pulled out of ninety two thousand five hundred and seven, and it was given its own code.
Rick Gawenda:Mhmm.
Jeanette Benigas:But it's valued at a lower valuation. So our companies don't receive as much reimbursement when we treat cognition. Also, from what I understand, there are a couple insurers who won't reimburse for it. And so now, like one of the companies that I do PRN for, it's not even a CPT code that I get to choose from when I give treatment. So when I give dementia treatment and that's one of my two specializations, I have to fraudulently bill that under 92,507 so my company can make more money.
Jeanette Benigas:Well, now we have a problem because auditory processing has been billed under 92,507. If these codes actually go into effect on 01/01/2027, where are you going to stick it? And also, this is another point. What about those insurers who aren't covering cognition? Now, how do we bill for that?
Jeanette Benigas:Somebody tell me, please.
Rick Gawenda:I mean, cognition has not been 92,507 for a long, long time. So again, I'm going to show each year. Ninety seven thousand five hundred thirty two, way back in the 90s was the development of kinds of skills. And that was a code for many, many, many years. And then it changed into 97127 around twenty seventeen twenty eighteen.
Rick Gawenda:And there somewhere and then went into the two current codes we have now 9700129 and 97130. And the reason there's two codes for cognitive function and counter strategy training is because the first fifteen minutes is 97129 That pays slightly more money than each additional fifteen minutes under 97,130. But to further make it worse, what you're saying, Jeanette, is there's this thing called NCCI edits.
Jeanette Benigas:Yes.
Rick Gawenda:And I can tell you the Medicare program and the Medicaid program do not allow SLPs to bill nine two five zero seven and nine seven one two nine nine seven one three zero, as well as nine seven five three three sensory integrative techniques on the same day as the one other. So again, what if you have that patient that needs each language, but they also need kinds of training the same day? But what do I think they're doing right now? They're lumping everything under nine to five or seven because of the untime code. Right?
Rick Gawenda:Well, now with these new codes, we haven't said this yet because you can't. I can. They're time based,
Jeanette Benigas:right?
Rick Gawenda:You can't take kind of training and put it into the speech codes because there's a specific code for kind of training. So could that open up, you know, you use the word fraud? We use fraud and abuse.
Jeanette Benigas:I like to name it what it is, Rick. I there's no sugarcoating on this platform.
Rick Gawenda:Before you before people listen to this podcast, you and I are doing maybe it was abuse. They didn't know they couldn't do it. After they listen to the podcast. Yeah, it now becomes fraud because fraud is, you know, it's wrong. You know, you shouldn't do it and you still do it.
Rick Gawenda:Right. So I do think that could become an issue. Yeah. Where SLPs just add time in for the kinds of training, the camps or strategy training, or they get where they add that into the new time based speech codes to increase the unit. But yet, it's not cognitive training.
Jeanette Benigas:And to be clear, I don't think like myself, like I called it out on myself, I commit fraud every time I go to work, not because I want to, because I'm being forced to. And there comes a point where we need to keep our jobs, right? We have to stay employed. And so if this is what's going on on the medical side, we're not really given a choice. So sometimes it's fraud by force.
Jeanette Benigas:So I don't want people to think I'm saying they're unethical because we are bound to the systems that direct us when we're at work. We can only do so much and we have to make paychecks and put food on the table for our families.
Rick Gawenda:And of course, I have to say don't do the fraud because I was right. To keep you out of jail. I do testify in federal court cases where there's a therapist being charged by the federal government. Want to put you in jail for fifteen, twenty years. My job is to, you know, with your attorneys to not have you go to jail.
Rick Gawenda:Obviously just be careful out there. And there's whistleblowers out there as well. And that's a whole different topic as well. I know it's kind of going off right now, which is fine. But don't commit fraud.
Jeanette Benigas:Don't commit fraud. Yes. So we've got this limited scope issue, which you might read about in the application. So something to start thinking about how do you feel about that? We have these billing issues, which the AMA doesn't care about money.
Rick Gawenda:That is true.
Jeanette Benigas:But we know this is gonna be a problem. We might not be able to build cognitive for some third party payers. Where are we gonna plug in auditory and comprehension? What else are we thinking about here, Rick, that's problematic with what has already been put forward and approved? Anything else?
Rick Gawenda:Well, again, 92507 is an untime code. And, you know, obviously the Medicare program pays that code basic in a national level, about $76 You know, obviously you got the Medicaid programs around the country, private commercial payers typically pay a percentage of what Medicare pays, whether it be higher or lower. While these new codes are going to be time based. And when you look at the five things I said, there'd be a new code for fluency, speech, sound, language, comprehension, expression, speech, sound, language, comprehension, expression combined, and then voice and resonance. So on those five, there's going to be an initial thirty minute code for each one of those.
Rick Gawenda:And then in each an additional fifteen minute code for each one of those. So from what I hear, of course, from SLPs, both medical SLPs and ones that do pediatrics, a lot of times their sessions only last twenty, twenty five, thirty minutes. Well, twenty minutes of speech therapy treatment or fifty minutes of speech therapy treatment right now you get the dollar amount that your contract allows. Well, in 2027, with these new codes being time based, do I expect the codes to pay less now for the initial thirty minutes? I do.
Rick Gawenda:So I think we're looking at a loss of revenue for say a thirty minute session.
Jeanette Benigas:We can't know exactly what those reimbursement rates are going to look like because some of those numbers aren't even out yet. We can make some guesses and assumptions. I see some platforms saying, Well, take a look, I know what it's going to be in my area. Well, no, you don't know. We have to be clear.
Jeanette Benigas:We don't know because some of these numbers aren't out yet. There's no way to know. We can look at trends and patterns. But would it be fair to say based on what's been put out in trends and patterns in the past, is there a general percentage like 20 or 25% that we might be looking at less for the first thirty minutes? Can we figure that out?
Rick Gawenda:It's going be hard.
Jeanette Benigas:Okay.
Rick Gawenda:So every CPE code is made up of what they call three relative value units. So right now, nine to five or seven has what they call a work RVU. It's like, I think 1.3. Yes, the practice expense RVU, I believe, is 0.97. And then the malpractice RVU is point zero one.
Rick Gawenda:Now for the new codes, we do know what is being proposed for the work RVUs. Yes. And I'm just going to use the one that speech sound and language comprehension expression combined for an initial thirty minutes. The work RVU that's being proposed is one point zero zero, which obviously is less than 1.3. However, what we don't know is gonna be the practice expense, RBU.
Rick Gawenda:Now we do know the rec committee is recommending a significant increase in the dollar amount for the direct input for the practice expense RVU, which includes your supplies, your clinical time, etc. So I think right now, 92,507 is about 3.36 For this new quote I just mentioned, I think they're recommending over $16.17 dollars What we don't know because of the complicated unknown formula CMS uses is how does CMS take that dollar amount for the PE recommendation and turn into a PE RVU. That's what we don't know. Right. Will the PE RVU be still be lower than 0.97?
Rick Gawenda:Will it be higher than 0.97? I mean, logic would say it should be higher because of all the additional equipment costs, clinical labor costs, etcetera. But we won't see what CMS is going to come out within the PERBU until CMS releases the proposed rule in July 2026 for 2027.
Jeanette Benigas:Let me ask this question. If the new proposal that has been put forward passes, if that is voted yes, we're going to vote this, revert back to what it was, go back to the table for renegotiation. Will those numbers be proposed in July by CMS?
Rick Gawenda:Doctor. If in this meeting, I won't say what's in the proposal course, let's just say that the new codes get delayed for some reason for 2020 or beyond, and the vote is to maintain 92,507 for 2027, then those proposed PEs would not come out. Right. Because obviously you're back at the drawing table with 10 new codes, trying to figure out new language, etc. Because of adding in the word communication, auditory processing disorder, Might that include additional clinical time, new supplies, different equipment that would all have to then go back to the rock?
Rick Gawenda:You know, once again, assuming what would happen in April, if that got these new codes got stopped somewhere down the road at a future meeting, whether it's a September 2026 meeting, the January 27 meeting, do these now new codes come back again that have been revised? Do they now get approved again by the CPT editorial panel? If yes, they then go back to the rec committee to go through the argue values again.
Jeanette Benigas:It's important for people to understand that during this open comment period, you are not going to know the values from CMS. If this gets to CMS, it's a lot harder to fight. That's when lobbying has to come into play, lots of money has to be thrown into this. And so maybe we like these work RVUs that The Rock put forward. We could keep those if we want to.
Jeanette Benigas:The purpose would be to get some of this language changed and revised. And then if we want to move forward with those work RVUs, I always told my students, your chance to make money is at the negotiation because we don't get cost of living raises in speech language pathology. We don't get pay bumps. The only way to get a pay bump is to change jobs truly. Over the last twenty years I've been working, if you want to make more, you've got to leave and go find a company that's going to pay you more.
Jeanette Benigas:Your current position probably isn't going to bump you the way that you want to be bumped. And there is a max. So we have to remember that pretty often there are Medicare cuts. There are cuts in our funding all of the time. And so this is the minimum.
Jeanette Benigas:This is the highest it's going to be probably for a long time. It only goes down from here. So we need to work to get this as high as possible because those cuts are coming, guys. They're coming. Okay?
Jeanette Benigas:And this is this is an effort to save money. I think Rick, right? Like they want to save money in this process.
Rick Gawenda:Well, the other thing I'm going to say first, if I answer that is keep in mind, the rock recommends the proposed work RV use. CMS does not have to accept their proposal, right? They can actually increase them or decrease them. Now, my experience in the twenty three years, I do a lot of stuff. They seem as does one or two things usually, they either accept the recommendations, or they don't accept them, and they actually decrease them.
Rick Gawenda:Is rare for CMS to not accept the RUC recommendation and to actually increase the RVU.
Jeanette Benigas:Right. So that's why this is the minimum. The likelihood we see these things go up is very low. So we might not see those recommendations in July, depending on what SLPs say and what the AMA decides to vote. But we could.
Jeanette Benigas:Well,
Rick Gawenda:my opinion is it's going to be one of three things. You know, that the vote goes, you know, does not go in in the favor you want to go in and these new codes go as is. To it goes in favor and we say we keep 92,507 for 2027. And these new codes do not go in? Or do people kind of agree and modify the current CPT codes to add in the language that maybe is missing and all that.
Rick Gawenda:And then could they then go forward that way? So you really have, I think, one of three options to go.
Jeanette Benigas:Yeah. Yeah, I've seen a lot of questions. So since we're talking about these RVUs and times and codes, I think this is a good place for me to ask some of these questions because I think there's a lot of confusion online, but there are rules about how these codes operationally can be used. So can you explain to everyone very clearly how many base codes you can use in a session? What maybe the midpoint rule means when you can add an add on?
Jeanette Benigas:What are you looking at? If you want to use a base and an add on, how many minutes are we looking at here? Can you explain all of that for everyone so it's nice and clear?
Rick Gawenda:Sure. So as we use the word base, that's going to be the five codes that we mentioned several times, each thirty minutes, we're going to call that quote, the base code. And I'm just going to use the one I think it's going to be nine. And when you look at this document, by the way, that's, you know, over 3,000 pages long, you won't see five numbers for these codes, you're going to see like a nine x zero x zero nine x zero x one nine zero x, you know, so on. Assuming these codes do go into effect for some reason, in September 2026, the AMA will publish the 2027 CPT book, at which time then you'll see the five numbers for these codes.
Rick Gawenda:So as I use nine x zero x six, that's going to be the treatment of speech sound and language comprehension and expression, the initial thirty minutes. So to build one unit of a thirty minute code, you got to get past midpoint. Now I know fifteen minutes and thirty one seconds is past midpoint, no one's got a stopwatch. So sixteen minutes is past midpoint, you could build one unit of a thirty minute code. Well, then to build that add on code, which would be nine x zero x seven, I believe, which is the each additional fifteen minutes of speech sound production and language comprehension expression, you have to do the full thirty minutes for the initial thirty.
Rick Gawenda:And then you have to do at least eight more minutes past that, because eight minutes is considered substantial of 15. So really to build the what we call the base code, the initial thirty minute plus one unit of a fifth each additional 15, you're going to do at least thirty eight minutes with that patient.
Jeanette Benigas:Right. Can two base codes be billed in the session for thirty minutes each?
Rick Gawenda:Yes, no, maybe so, depends.
Jeanette Benigas:If you give an hour of therapy, can two base codes be billed?
Rick Gawenda:The reason I say yes, maybe so depends. There's going to be some codes that can't be billed the same day because if you are billing the base code for speech sound production and language comprehension expression, you can't build a base code for just speech sound or just build the base code just for language comprehension expression. So that's why I'm, you know, you're to see that. So let's just say you had a patient that needed speech sound production and language comprehension expression, and you spend twenty twenty five minutes providing interventions to address those issues, you could go that base code, which I believe is nine x zero x six, I believe for the initial thirty minutes. Well, what if that person maybe also had some voice and resonance issues that you also wanted to address and you spent, say, twenty minutes doing that?
Rick Gawenda:You could then build a base code for that code for the initial thirty minutes. So if the patient has, you know, separate issues that are described by the different CPT codes, you could build a base code for speech, sound language, comprehension expression, and perhaps the base code for say voice and resonance, or the base code for fluency if you did it for at least sixteen minutes.
Jeanette Benigas:I had a post that went up. It's our blue post. That's what you're looking for. About February 2026 RUC recommendations, what it says about ninety two thousand five hundred seven. That was the post.
Jeanette Benigas:I got a little crafty and there there was one or two people who picked up on what I put down because I don't actually know the answer. So you might. The one of the examples I gave was a one hour session. The person has dysarthria and aphasia, expressive aphasia.
Rick Gawenda:Okay.
Jeanette Benigas:So we're we're doing this language treatment and there's dysarthria. Some dysarthrias, you treat residents, which is a different code.
Rick Gawenda:Mhmm.
Jeanette Benigas:So in this scenario, what code are we billing if we're working on resonance, which is one code? Mhmm. But it's to treat dysarthria, which is speech sound disorders, that's another code. Which one there are we billing and does that open us up for an audit? Are there rules defining that or are we in again in some trouble on how all this is laid out?
Rick Gawenda:Well, think it's going come down to the documentation of SLP and his or her intent. What are they really focusing on? Because even right now, when you look at the evaluation code, you've got speech sound production, which is dysarthria, and then you get the voice and resonance. So I guess I come back and go, well, which eval did you bill? Did you build the speech sound 92,522 eval?
Rick Gawenda:Or did you build the 92,524 for the voice?
Jeanette Benigas:You probably build the speech sound disorder one, because if it's someone with aphasia and they have a speech sound disorder, it's probably apraxia or dysarthria, you're probably billing speech sound disorders.
Rick Gawenda:Speaker Yeah. I think in my opinion, if these did go into effect and they stay as they they are, think you're looking really at the treatment code for speech sound.
Jeanette Benigas:Okay.
Rick Gawenda:And just analogy I'll use, obviously PT and OT, as you know, as so many SLPs know, we've got way too many codes. We've got a code for therapeutic exercise, which is, you know, I'll dummy this down, it's range of motion strengthening, neuromuscular education, balance coordination posture, and then you get good old therapeutic activity, which is dynamic functional activity. We're seeing logic here. You know, when I've got a child going supine to prone, kneeling, cruising, crawling, I've got an adult working on lunges or the simulation of functional activities. You know, as I'm doing all this, is range of motion strength involved.
Rick Gawenda:Absolutely. Is balance posture coordination involved? Absolutely. But I'm doing it during a functional activity. And if that's what I'm really the intent of it is, you know, I'm going with the therapeutic activity code.
Rick Gawenda:So using that same logic, I can understand SLP working on resonance and all that. But is it really for the dysarthria? And does that really take you then back to that treatment code for speech sound production?
Jeanette Benigas:Our documentation will have to be much more specific, right? And I think the larger conversation that we're having here and some of the problems that I personally have with this new structure is that we don't operate in silos as speech language pathologists. For those who don't listen, who don't know me, I was a neurology professor for years. And the first thing I thought of was this takes us all the way back to phrenology. And so for people who don't know what phrenology is, you Google phrenology and you'll see, maybe I'll throw it up online somewhere, it's when the brain is segmented into different numbers and zones and different parts of the brain do different things and we treat very specific areas of the brain and there is no overlap.
Jeanette Benigas:And we know now that that is simply not true. And you can have any number of delays or disorders or issues, and they're all going to overlap. You can have a cognitive disorder and have a language problem as part of cognition. So now are you treating cognition or are you treating language? You know, you could have an attention problem, which is cognition, that's impacting your language.
Jeanette Benigas:And so we don't have a lot of wiggle room for taking advantage of a moment in time when when maybe we're like, oh, let's shift from this to this because this is really where this session is going. Think especially with little kids. I worked with kids for a few years. Sometimes you just have this has to be a child led thing, right? Or the life participation approach for people with aphasia.
Jeanette Benigas:If you're getting in there digging into their life and helping them compensate for their loss, there is no silo that we can bill. It is all overlapping. What these codes are really preventing us from doing with a thirty minute construct is allowing us wiggle room to bill multiple codes in thirty minutes or forty five minutes or an hour. And I know this is one of the reasons why the team said, you just need to see this because as a medical SLP, we have been screaming for timed codes for years because of the abuse that we see in our jobs. Right now, the one PRN job, same one where I can't do cognition, this is one of the most ethical companies I work for, by the way.
Jeanette Benigas:I'm allowed to see people for twenty minutes. Twenty minutes. We've been asking for that, like an eight minute code. You and I have talked about those days might be gone. But timed codes that are valued appropriately, that allow us to switch and combine and do the things we need to do in a very short period of time or even a longer time so we can spend more time with patients, more than fifteen or twenty minutes.
Jeanette Benigas:And that's what we've been yelling for all along. But now what these times are doing, in my opinion, in healthcare is making it even harder. Because if I need to treat all of those things, plus by the way, we haven't even talked about adding dysphasia into all of this, which is 65% of what we do in healthcare, we're really limiting what we can do. And I think even if the money comes out kind of equal for a forty five minute session, Now our employers have to pay us for fifteen minutes extra. Let's say we're at that 70, let's call it 70 or 75.
Jeanette Benigas:Maybe they were getting it, allowing us thirty, twenty or thirty minutes before, but now we need to work forty five minutes for them to get the same. Our pay is going down, folks. They still have a business to run. They're not getting reimbursed more. You see eight patients in a day times fifteen minutes extra.
Jeanette Benigas:That's two hours of work. They're not making extra money for it and they still have to pay me or you. We've got problems. So I don't want people to see or start trying to see a lot of fighting on these values online. Even if it looks like it could be good, we still have a problem in the back for the person running the business.
Rick Gawenda:And I agree with everything you said. You don't work in a silo. But as you look at 92507, obviously, this code hasn't been looked at in many, many years. And obviously, the supplies that are being used now, equipment treat from pediatric geriatrics has changed drastically as a higher cost, etc. Unfortunately, I just think organizations and practices kind of abuse 92507 being an untime code.
Rick Gawenda:Yeah, you know, you know, CMS looks at that code as SRP spending fifty minutes one on one. There's like five minutes pre service time five minutes post. I can guarantee that's not happened anywhere in the country. Nope. When you look at I don't know if you saw North Dakota Medicaid just changed on February 1, that if the SLP spends less than 35 minutes with the child, they have to put a special modifier on that then reduces payment to half of the allowed amount.
Rick Gawenda:So I'm just going to throw out to you. Look at 92,507. If you're happy with that descriptor, keep that descriptor. Why not have the initial 92,507 initial fifteen minutes? Add a new code each additional fifteen minutes.
Rick Gawenda:Yeah, with that's all for it. Again, it all for it. Again, money aside, I think that's the most sense because every LLSR piece I'm talking about telling me 92,507 encompasses everything we do doesn't lock us into a silo, which I agree with everything you said. Yeah, because these and OTs were locked in the site almost silos with all these freaking different codes we have. We got to figure out which one to bill and how to write a a thesis to support Xerox today or neuro tomorrow or 50 ks is the next day.
Rick Gawenda:Why not look at 92507 initial fifteen minutes create a new code each additional 15. Do the surveys, look at all the equipment is now being used to treat voice, speech, language, communication, auditory processing disorder, just get it valued better. Yeah. Something that could be brought up in comments at that meeting.
Jeanette Benigas:Yes. And something else people can be looking at that is part of this structure that can be addressed, think in some of the feedback people want to give is start looking at your day. So the assumption of these new codes was 75% of the time only one code is going to be used and 25% of the time there will be more than one code. I don't know in my day that I agree with that. Start checking because this is what the surveys told them.
Jeanette Benigas:Right? And so start checking that because if you want to somehow talk about that, if it's appropriate in what you have to say, you can say that. Or if this thing goes back to the drawing board, we need people speaking up and saying, no, no, no. 75% of the time, I would be doing more than one of these codes. And I think we need to be collecting our own data to know what we're actually doing, because I'm willing to bet that productivity driven clinicians or, you know, pediatric pediatrics aren't always on productivity.
Jeanette Benigas:But when you're working with kids in the half hour session, you're probably using more than one of these codes. So it's just my guess. So everybody has to look for themselves and be be ready and armed with that information when you're asked for it because these codes were based on information from somewhere between 50 something and 80 something responses, and we might not have had a good representation. So I know we need to wrap up, Rick.
Rick Gawenda:Yeah.
Jeanette Benigas:What do we want to tell people whether when they read this packet, they love it, they hate it. Do we want to give some advice on really some tips that you think they should be focusing on? I can't do that. I can't sway you one way or another, but I think Rick can at least give you some pointers on what to do. And then you'll see this in our content Yeah.
Jeanette Benigas:Through the next week or two.
Rick Gawenda:Obviously, human nature, I would be honest. It's where you're gonna focus is the work, the proposed work RVUs, you're try to figure out the PE time and all that money stuff. Don't focus on that. I think what's extremely important as you begin that reading on page 2,836, And you kind of go, I would just focus on the codes that were proposed, and how the rationale behind them. And as Jeanette said, you know, how often do you think you're going to do just that code compared to other codes?
Rick Gawenda:Because I do agree that SLPs do not work in silos, whether it's peds to adults to geriatrics. Your clients have multiple speech and language issues that are going to fall in different areas. And I think it's very cumbersome then to try to figure out how to document everything, meet that sixteen minute threshold on the billing side. But I think just go through, look at the rationale behind it. Do you agree with it?
Rick Gawenda:What do you think about the words, auditory processing disorder being missed? Me? Yeah, I think that puts you at risk Because if you are now working on that with a child in '27 or '28, and you're billing under one of these five new codes, a payer can go back and say that's not included in that code. You know, we can debate the word communication all we want, whether you we think it's inherently included in speech sound, anything else or it's not weird. I think the insurance company is going to say, Nope, don't see the word communication here.
Rick Gawenda:Right? Not going to pay for that. So exactly. We need to look at are you happy with the descriptors of the codes or things missing? If things are missing, is your goal then to get those words in one of the existing five, create a sixth or seventh new code?
Rick Gawenda:Or do we go back to ninety two thousand five hundred seven, look at change it to the initial 15, create another code each additional 15. But that's where we need to focus. I'm going to say it. CPT editorial panel does not care about money. When Jeanette goes to speak in Boston and the other people that are going to speak, They're not speaking money.
Rick Gawenda:You know, they don't care about money. The argument is these codes do not accurately describe what we do as SLPs. We do not work in silos. We're missing this. We're missing this.
Rick Gawenda:We're missing this. Nope, 75% is not right. Boom, boom, boom. That's where the focus has to be. Again, obviously, know Jeanette has a huge following.
Rick Gawenda:How she wants to get comments from all of you, guess would, you know, I'll let her say, but somehow we get these comments and thoughts to her. But also we need to get you all when this opens up to submit comments because numbers do matter. Volume does matter. I know there a there was a PTOT thing several years ago that was open for comment. CMS got over 10,000 letters from PTs.
Rick Gawenda:We won because 10,000 letters. Now said the same thing. That was fine. They had to read them all. And they did not implement what they were going to implement.
Rick Gawenda:We stopped it. So is it possible? Yeah. Absolutely. But you've been cohesive.
Jeanette Benigas:You know what, Rick? There's something with this community that I've termed the Fixer Effect and it is real. I mean, we've heard from that AMA office that they're already getting inundated and I'm telling people to hold off. And so the Fixer Effect is a real thing. And we have powerful, smart, capable individuals in this field.
Jeanette Benigas:When you tell them go, they are going to go like they're already going and we haven't even said go yet. And I believe this community is already rallying around this so much that if this is something that we want or something that we don't want, whatever it is collectively, one voice, have to believe it's going to happen because I've already seen smaller changes just in little pods of Fearless Fixers working together. This is the entire community. And so one voice is really important. Now let me ask you this question.
Jeanette Benigas:People who have signed that confidentiality agreement, you're allowed to talk amongst yourselves, right? I know it's there. Once somebody reads it and puts in their comment, they can talk to me about what they've read, correct?
Rick Gawenda:I believe so. I have to go back and read the language again.
Jeanette Benigas:Okay, I will too.
Rick Gawenda:Affinuated agreement while it says that I believe if we if somebody else has signed it, we can discuss it between ourselves. It's just if somebody has not signed it. They Right. And that's obviously when I you know, so as you know, I had to do a lot of record behind the scenes quiet. Obviously, you got to meet me because of people I was able to assist and they got put in the you and just see how it kind of evolves and it's just rolling right now.
Rick Gawenda:Like a big snowball going downhill.
Jeanette Benigas:Doctor. It's wild. I would say that's the next thing because I'm just one person with one brain. And I know that our community is so incredibly smart. It's been one of my biggest frustrations with the legal action we're planning outside of this that had to be paused is I keep telling the lawyer, wish I could just tell everybody this because then we'll nail it.
Jeanette Benigas:But this is the thing, after you sign that and you put in your comment, I want to hear privately what you think because I already have some talking points that I think I should say in that editorial panel meeting, But there are so many smart people who maybe can say it a better or different way because let's be honest, I'm not always refined. Okay, I'm gritty. I'm a real person. I'm not polished. So you might have a better polished way.
Jeanette Benigas:You might have a point we didn't even think of. And so I want to take this collective voice into that room and represent it well. We just can't put those points out online because there will be people there that haven't signed the confidentiality agreement. So with that, Rick, I think I've kept you over. Who knows if we'll have you back?
Jeanette Benigas:This thing changes every day, but for now, this is it from you, least on our podcast. I'm so thankful that you've done this with us. I hope people have enjoyed this extra long episode. But yeah, yeah guys, I'll keep engaging with you online, keep asking questions, head to my YouTube. My YouTube is where those videos will be.
Jeanette Benigas:You can subscribe and things will be there if you want to review it all before you write. That's the goal now. For me, my mission is figure out what I'm going to say in that room and get education out to you so you can make an informed response. So thank you, Rick.
Rick Gawenda:Thanks for that.
Jeanette Benigas:Anything else you want to say before we go?
Rick Gawenda:No, appreciate you having me. Hopefully, will be talking again sometime soon.
Jeanette Benigas:Yeah. Yeah. Alright, everybody. Thanks for fixing it. Thanks for listening to the Fix SLP podcast, the podcast shaking up the field of speech language pathology.
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