2027 Medicare Part B Final Rule: Coding, Payment, and Policy Analysis

November 10, 2026

The Centers for Medicare & Medicaid Services (CMS) has released the final 2027 Medicare Physician Fee Schedule (MPFS). The rule establishes Medicare Part B outpatient payment and policy changes for audiologists and speech-language pathologists (SLPs) beginning on January 1, 2027. This analysis explains the final decisions, their potential effects on payment, and steps clinicians can take to prepare.

The rule establishes Medicare payment and related policies for the new Current Procedural Terminology (CPT®) codes replacing 92507 and for new vestibular testing codes. It also addresses remote monitoring services and broader Medicare payment policies. These include changes to practice expense calculations and the conversion factor—the dollar amount used to turn a service’s relative value into a payment rate. The new coding structure and these broader payment policies can both affect payment.  

ASHA submitted formal comments [PDF] on the proposed 2027 Medicare Physician Fee Schedule, urging CMS to accurately reflect clinical work and practice expenses, reduce unnecessary administrative burden, and protect access to medically necessary care. Member petitions on audiology [PDF] and speech-language pathology [PDF] policies supported this advocacy.


The Top Line

New Audiology and Speech-Language Pathology Codes

  • CMS finalized implementation of 10 new speech-language pathology treatment CPT codes and four new vestibular diagnostic CPT codes.
    • Five of the new speech-language pathology codes may be subject to a Multiple Procedure Payment Reduction as required under federal law, something ASHA has been actively advocating against.
  • CMS accepted 13 of the 14 AMA Relative Value Scale Update Committee (RUC) recommendations for the new codes. It finalized a lower work value for one vestibular testing add-on code, reducing payment for that service.
  • CMS finalized a new Medicare-specific Healthcare Common Procedure Coding System (HCPCS) code, G0903, for pediatric speech-language pathology treatment. ASHA is concerned that the code could create confusion, increase administrative burden, and reinforce outdated payment policies.

Medicare Payment Updates

  • CMS will reduce the 2027 conversion factor by 2.31% for most clinicians who do not participate in a qualifying Alternative Payment Model.
  • ASHA estimates that changes to how practice expense is calculated could reduce payment for many existing services by approximately 5%.
  • CMS estimates overall Medicare payment to most audiologists could decrease anywhere from 2% to 5%, depending on services provided. Because speech-language pathology is grouped with physical and occupational therapy, the rule does not provide a separate estimate for SLPs, but they should anticipate a reduction.
  • Legislation in Congress could help mitigate these cuts and provide long-term solutions.

Other CMS Policy Highlights

  • CMS increased the KX modifier threshold to $2,540 while maintaining the targeted medical review threshold at $3,000 as required under federal law.
  • CMS finalized new oversight requirements for remote therapeutic monitoring services.

    What ASHA Is Doing and Member Advocacy Opportunities

    • ASHA continues to develop free educational resources to help members prepare for the 2027 policies, including several December webinars covering topics like understanding the MPFS final rule and preparing for coding changes.

    On this page:

    CPT and HCPCS Coding Updates

    CMS finalized Medicare payment for the following new codes:

    • four new CPT codes describing vestibular diagnostic services;
    • 10 new CPT codes describing individual speech-language pathology treatment services; and
    • a new HCPCS Level II code, G0903, for pediatric speech-language pathology treatment services.

    The American Medical Association (AMA)/Specialty Society Relative Value Scale Update Committee (RUC) recommends to CMS the clinical work and practice expense resources associated with CPT codes. CMS considers those recommendations but makes the final decisions about Medicare valuation and payment. Learn more about how this process works: Understanding the CPT® Process: How Codes Are Created and Valued.

    A note about the final payment amounts: Most audiologists and SLPs are expected to be paid under CMS’ 2027 conversion factor of $32.6286 for clinicians who do not participate in a qualifying Alternative Payment Model. The national payment amounts below use this conversion factor and will vary based on geographic and other Medicare payment adjustments. Additional information about the conversion factors and broader payment policies appears later in this article.

    CMS has not yet finalized the National Correct Coding Initiative (NCCI) edits for the new audiology and speech-language pathology codes. These edits help determine which services may be reported together on the same date of service. ASHA will advocate for appropriate edits and update its coding resources when the final edits are released.

    Audiology Coding Updates

    Beginning January 1, 2027, the CPT code set will add two new codes describing video head impulse testing (vHIT) and two new codes that replace CPT code 92546 for rotational vestibular assessment using sinusoidal harmonic acceleration (SHA) and velocity step testing (VST). CPT code 92546 will be deleted from the CPT code set effective January 1, 2027.

    CMS accepted the RUC-recommended work values for three of the four new vestibular codes. For the VST add-on code, 92528, CMS finalized a work relative value unit (RVU) of 0.35 rather than the recommended 0.48, despite ASHA’s opposition. Compared with the recommended values, this lower value reduces Medicare payment for that service.

    CMS added all four new vestibular testing codes to the Medicare audiology services code list. However, none of the codes will be added to the separate list of services eligible for billing with the AB modifier. The AB modifier list is limited to certain nonacute hearing assessment services provided without a physician order and does not apply to vestibular function tests. Learn more about Medicare hearing assessments provided by audiologists without a physician order, including when and how to use the AB modifier.

    The table below lists the work, nonfacility practice expense (PE), malpractice (MP), and total relative value units (RVUs) for the four new vestibular codes, with estimated national Medicare Part B nonfacility fee schedule amounts. Full code descriptions and coding information and instructions are available in CMS Proposes Medicare Payment for New Vestibular CPT Codes.

    CPT Code

    Short Description

    RVUs (Nonfacility)

    National Payment

    Work

    PE

    MP

    Total

    92513

    vHIT of lateral semicircular canal function

    0.53

    0.39

    0.01

    0.93

    $30.34

    92514

    vHIT of lateral and vertical semicircular canal function

    0.84

    0.59

    0.01

    1.44

    $46.99

    92527

    Rotational vestibular assessment by SHA testing 

    0.92

    1.24

    0.02

    2.18

    $71.13

    +92528

    Add-on code for VST when performed with SHA testing

    0.35

    0.39

    0.00

    0.74

    $24.15

    Speech-Language Pathology Coding Updates

    CPT Codes for Speech-Language Pathology Treatment Services

    Beginning January 1, 2027, CPT code 92507 will be deleted from the CPT code set and replaced by 10 new codes that modernize the code set and more specifically describe individual speech-language pathology treatment by clinical focus and treatment time.

    This new code family includes five treatment categories for:

    • fluency disorders;
    • speech sound production disorders;
    • language comprehension and expression disorders;
    • speech sound production and language comprehension and expression disorders; and
    • voice, upper airway dysfunction, and/or resonance

    Each category includes a base code describing the initial 30 minutes and an add-on code describing each additional 15 minutes. For more details on the new codes, see Speech-Language Pathology Treatment Codes Replacing 92507.

    Note: Medicare’s decisions can influence Medicaid and commercial insurance policies, but they do not establish one payment rate or set of billing requirements for every payer. Confirm each payer’s coverage, rates, authorizations, and transition instructions. See Why Medicare Matters—Even if You Don’t Bill Medicare for an explanation of how Medicare’s decisions may affect other payers.

    CMS accepted the RUC-recommended work RVUs and direct practice expense inputs for all 10 new codes without changes. Final payment also reflects the conversion factor, CMS’ calculation of practice expense RVUs, and other applicable payment policies. Acceptance of these recommendations does not mean that payment is unchanged or higher for every treatment session.

    All 10 codes require a therapy plan of care and the appropriate therapy modifier, such as GN, for a speech-language pathology plan of care. CMS calls these “always therapy” services because they must always be provided under a therapy plan of care.

    The five base codes (92654, 92656, 92658, 92660, and 92662) are subject to Medicare’s existing therapy Multiple Procedure Payment Reduction (MPPR) policy. When multiple eligible therapy services are billed for the same patient on the same day under applicable Medicare billing-provider rules, Medicare reduces the practice expense portion of payment for additional eligible services.

    The five add-on codes for each additional 15 minutes (92655, 92657, 92659, 92661, and 92663) are excluded from the MPPR. Learn more in Calculating Medicare Fee Schedule Rates and Medicare Multiple Procedure Payment Reductions (MPPR) Scenarios for Speech-Language Pathology Services.

    Urge Congress to eliminate this unfair penalty that lowers Medicare provider payments and limits access to services by writing a letter today.

    How MPPR Applies to the New Codes

    MPPR reduces the practice expense portion of payment—not the total payment. Medicare pays the full work and malpractice portions of all eligible therapy services. For the same patient on the same day, Medicare pays:

    • 100% of the practice expense portion for the service with the highest practice expense value; and
    • 50% of the practice expense portion for each additional MPPR-eligible service.

    An SLP provides 45 minutes of language treatment. The patient receives no other MPPR-eligible therapy that day. The SLP reports:

    • 92658: Initial 30 minutes of language treatment
    • +92659: Each additional 15 minutes

    Result: No MPPR reduction applies. Although the base code is subject to MPPR, the add-on code is excluded. Because there is only one MPPR-eligible service, Medicare would not reduce the payment.

    An SLP provides 45 minutes of speech-language treatment. Later that day, another SLP in the same practice provides medically necessary swallowing treatment for 25 minutes to the same patient. For this example, assume the services meet applicable coverage, documentation, billing-provider, and NCCI requirements. The SLPs report:

    • 92660: Initial 30 minutes of speech-language treatment
    • +92661: Each additional 15 minutes of speech-language treatment
    • 92526: Swallowing treatment (untimed code)

    Result: MPPR applies to the two eligible services—the speech-language treatment base code and 92526—because they were provided to the same patient on the same day. Medicare would pay the full practice expense amount for 92660 because it has the higher practice expense value and 50% of the practice expense amount for 92526. The work and malpractice portion for each code remain payable in full. The add-on code, 92661, would not be reduced because it is excluded from MPPR.

    This scenario also applies when an SLP and a physical or occupational therapist provide MPPR-eligible services to the same patient on the same date of service, even when the services are provided by different practices or in different settings.

    Understanding RVUs and Payment Rates for the New Codes

    Payment under the new coding structure varies by treatment type and duration. Some treatment scenarios may be paid less than services currently reported with 92507; others may be paid more. To assess payment changes, compare the same clinical service and treatment duration under the 2026 and 2027 rules, including eligible add-on units and applicable payment adjustments, such as MPPR. A comparison using a 30-minute base code alone does not capture payment for a longer session.

    The table below lists the work, nonfacility practice expense (PE), malpractice (MP), and total RVUs for the 10 new codes, along with the national Medicare Part B nonfacility payment amounts. Full code descriptors and additional coding information are available in Speech-Language Pathology Treatment Codes Replacing 92507.

    CPT Code

    Treatment Category and Time

    RVUs (Nonfacility)

    National Payment

    Work

    PE

    Malpractice

    Total

    92654

    Fluency disorders—initial 30 minutes

    0.92

    0.67

    0.01

    1.60

    $52.21

    +92655

    Fluency disorders—each additional 15 minutes

    0.44

    0.29

    0.00

    0.73

    $23.82

    92656

    Speech sound production disorders—initial 30 minutes

    0.90

    1.09

    0.01

    2.00

    $65.26

    +92657

    Speech sound production disorders—each additional 15 minutes

    0.44

    0.29

    0.00

    0.73

    $23.82

    92658

    Language comprehension and expression disorders—initial 30 minutes

    1.00

    0.51

    0.01

    1.52

    $49.60

    +92659

    Language comprehension and expression disorders—each additional 15 minutes

    0.48

    0.22

    0.00

    0.70

    $22.84

    92660

    Combined speech sound production disorder and language disorders—initial 30 minutes

    1.00

    1.16

    0.01

    2.17

    $70.80

    +92661

    Combined speech sound production disorder and language disorders—each additional 15 minutes

    0.50

    0.35

    0.00

    0.85

    $27.73

    92662

    Voice, upper airway dysfunction, and/or resonance disorders—initial 30 minutes

    0.98

    0.69

    0.01

    1.68

    $54.82

    +92663

    Voice, upper airway dysfunction, and/or resonance disorders—each additional 15 minutes

    0.48

    0.25

    0.00

    0.73

    $23.82

     

    Same-Day Billing Restrictions for the New Treatment Codes

    Although CMS considers the 10 new CPT codes to be replacements for CPT code 92507 and anticipates that the existing billing rules associated with 92507 will generally carry over to the new codes, CMS also emphasized that clinicians must refer to the National Correct Coding Initiative (NCCI) edits for applicable billing restrictions. Because NCCI edits fall outside the scope of the Medicare Physician Fee Schedule (MPFS) rulemaking process, specific billing restrictions and code combinations will not be fully clarified until the updated NCCI edits are released in early 2027. ASHA will comment on any proposed NCCI edits that apply to the new codes and continue to update members as additional details become available.

    Services Provided via Telehealth

    All of the 10 new speech-language pathology treatment codes are on the Medicare Telehealth Services List. Code list inclusion is separate from audiologists’ and SLPs’ authority to provide Medicare telehealth services, which Congress has extended through December 31, 2027. See Providing Audiology and Speech-Language Pathology Telehealth Services Under Medicare.

    Group Treatment

    CPT code 92508 will remain available as an untimed code for group speech, language, voice, communication, and/or auditory processing disorders for two or more individuals. Its descriptor and coding instructions have been revised so that the code stands on its own after CPT code 92507 is deleted.

    CPT Code

    Short Description

    RVUs (Nonfacility)

    National Payment

    Work

    PE

    MP

    Total

    92508

    Group speech, language, voice, communication, and/or auditory processing disorders for two or more individuals

    0.28

    0.30

    0.01

    0.59

    $19.25

    Pediatric Speech-Language Pathology G Code

    Beginning January 1, 2027, CMS will adopt G0903, an untimed Medicare-specific HCPCS code for individual pediatric speech-language pathology treatment. It was identified as GSLPP in the proposed rule. Unlike the new CPT codes, CMS created this code separately from the AMA CPT and RUC processes in response to feedback from interested parties that the new CPT code set may not adequately represent pediatric treatment services. The following guidance describes Medicare’s policy; other payers must confirm their own requirements.

    Coding and Billing Guidelines

    CMS describes G0903 as preserving the billing flexibility of 92507 and noted that all billing rules associated with 92507 will apply to G0903. Clinicians must also follow the specific requirements outlined by CMS below.

    Patient age and code selection: Medicare permits using G0903 for eligible patients age 21 and under, through age 21 years and 364 days. For these patients, clinicians may select either G0903 or the applicable new treatment codes, depending on which most appropriately describes the services provided. G0903 is not required solely because of the patient’s age. G0903 is not available for patients aged 22 or older; clinicians must use the applicable 10 new treatment CPT code(s) for their services.

    CMS states that G0903 and the 10 new CPT codes are mutually exclusive and cannot be reported together. CMS has not provided detailed guidance for choosing between G0903 and the new code set.

    ASHA has reached out to CMS for further guidance regarding appropriate code selection and will provide more details as they become available.

    Treatment time and reporting limits: G0903 is untimed and may be reported only once per patient per day. CMS clarified that, like 92507, there is no minimum session length or billing time threshold. For more information on billing untimed codes, see Understanding Timed and Untimed CPT Codes.

    Same-day billing requirements: Clinicians must check the NCCI edits, once released, for specific same-day billing restrictions. For example, the NCCI edits may carry forward existing restrictions on billing cognitive treatment codes 97129/97130 with G0903 on the same date of service. ASHA will update its NCCI resources once the edits are released.

    Other Medicare billing requirements: CMS also finalized the following requirements:

    • Therapy plan of care and modifier: G0903 is an “always therapy” service, meaning it must be furnished under a therapy plan of care and billed with the GN modifier when reported by an SLP.
    • Telehealth: G0903 will be included on the Medicare Telehealth Services List beginning in 2027, subject to Medicare’s other telehealth coverage and provider eligibility requirements.
    • MPPR: G0903 is subject to the therapy MPPR policy, which can reduce the practice expense portion of payment when multiple applicable therapy services are furnished to the same patient on the same day by the same provider. This policy can apply across physical therapy, occupational therapy, and speech-language pathology services.

    Payer adoption: Medicaid programs and other payers may choose whether to adopt G0903. Before using the code, clinicians should confirm whether each payer accepts it and what coverage, documentation, authorization, and billing requirements apply.

    Valuation and Payment

    CMS based G0903’s work value and direct practice expense inputs on 92507. It assigned a work RVU of 1.30 using a 60-minute valuation assumption. This assumption is used to value the service; it is not a minimum session length or a requirement to provide 60 minutes to bill G0903, since it is an untimed code.

    In the rule’s narrative, CMS finalized its proposal to maintain the 2026 PE RVU of 0.97 associated with CPT code 92507 for G0903, with the stated intention of preserving comparable payment rates between the two codes. However, CMS’ final 2027 payment file, which lists the RVUs used to calculate Medicare payment, assigns G0903 a nonfacility PE RVU of 0.72. This lower value reflects the application of CMS’ revised PE methodology, which also reduced PE RVUs for other CPT codes. This, in conjunction with the lower conversion factor, resulted in a lower overall payment for G0903 than the 2026 payment for 92507.

    The payment table below therefore uses 0.72, the value published in the final payment files, rather than 0.97 cited in the rule’s narrative. Despite CMS’ stated intention to preserve comparable payment, the lower PE RVU reduces the PE portion of payment for G0903.

    The following table summarizes the work, practice expense (PE), malpractice, and total RVUs for G0903, along with the estimated national Medicare Part B nonfacility payment. Due to federal legislative budget neutrality requirements and CMS’ revised PE methodology, the national payment for G0903 in 2027 is approximately $10 lower than the 2026 national payment rate for CPT code 92507.

     

    HCPCS Code

    Short Description

    RVUs (Nonfacility)

    National Payment

    Work

    PE

    MP

    Total

    G0903

    Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual; for the pediatric population age 21 and under

    1.30

    0.72

    0.01

    2.03

    $66.24

    Why ASHA Opposed the Pediatric G Code

    ASHA opposed G0903 because it risks recreating the same underlying problems that made 92507 unsustainable. A broad, untimed code may offer short-term billing flexibility, but it does not resolve the difficulty of accurately describing—and supporting appropriate payment for—the range of pediatric speech-language pathology services.

    When different types and lengths of treatment are reported under a single code, payers have limited information about what care patients receive and why the resources required vary. Over time, that lack of detail can make it harder to demonstrate the value of treatment, explain changes in service use, and defend payment that reflects clinicians’ work and patients’ needs. These were central challenges with 92507. Recreating that structure for pediatric services leaves clinicians exposed to similar scrutiny and payment pressures in the future.

    Specifically, G0903:

    • Carries forward an outdated valuation framework. Its valuation relies on work and practice expense inputs from 92507 rather than a new assessment of contemporary treatment and resource needs, including supplies and equipment.
    • May inadequately recognize longer or more complex treatment. A single payment amount does not distinguish differences in treatment time or clinical focus, potentially obscuring the resources needed to serve patients with greater needs.
    • Limits the information available to support future payment advocacy. A broad service description makes it difficult to distinguish treatment provided, time spent, and patient needs when payers review utilization or question spending growth.
    • Adds billing complexity. Maintaining a separate pediatric code alongside CPT codes that already describe services across age groups can create age- and payer-specific requirements for similar care. This variability can lead to coding errors and claim denials. Correcting claims adds administrative work and delays payment, further straining practice and facility finances.

    ASHA recognizes why an untimed option may appeal to clinicians seeking flexibility for pediatric sessions. The concern is what that option could mean for the long-term recognition and payment of their services. Flexibility alone does not address the underlying limitations of the code’s description and valuation.

    Because relatively few Medicare beneficiaries are younger than 22, the broader impact will depend largely on whether Medicaid programs and other payers adopt G0903. Adoption could extend these limitations across pediatric practice, while inconsistent adoption could require clinicians to navigate different coding approaches for similar services. ASHA will continue engaging with payers and monitoring implementation to address these concerns.

    Remote Therapeutic Monitoring Services

    CMS finalized several changes to strengthen oversight of remote therapeutic monitoring (RTM) services, which SLPs may bill but have not widely used under Medicare:

    • The policies limit RTM to established patients.
    • The policies require an in-person or telehealth visit to initiate services. CMS clarifies that beneficiaries already receiving RTM services before this policy becomes effective January 1, 2027, do not need to have an initiating visit solely because this policy takes effect as long as all other requirements are met.
    • The policies require clinical staff furnishing RTM services to be directly employed by the practitioner or the practitioner's practice, prohibiting the use of staff from third-party companies to furnish and bill for these services.

    CMS did not finalize its proposal to eliminate direct practice expense inputs for remote monitoring codes 99470, 99457, 99458, 98979, 98980, and 98981.

    Broader Medicare Payment Policies

    Medicare payment depends on more than the value assigned to a CPT or HCPCS code. Final rates also reflect the annual conversion factor, CMS’ practice expense methodology, and statutory and regulatory adjustments across the MPFS. These policies can change payment even when CMS accepts the recommended work and practice expense values for a code.

    Conversion Factors

    The conversion factor (CF) is the dollar amount used to turn geographically adjusted RVUs into Medicare fee schedule payment amounts. Every year, CMS updates the CF, which helps calculate MPFS payment rates. Federal law establishes separate conversion factors for clinicians who qualify for certain Advanced Alternative Payment Models (A-APMs) and those who do not. The 2027 conversion factors are:

    Participation Status

    Conversion Factor ($)

    Change from 2026 (%)

    Qualified APM Participants

    $32.9548

    -1.83%

    Clinicians Not in a Qualified APM

    $32.6286

    -2.31%

    Most audiologists and SLPs do not participate in a qualifying APM and therefore would be paid using the lower conversion factor ($32.6286).

    The amounts reflect several adjustments required under current law. Qualifying APM participants receive a positive 0.75% statutory update; other clinicians receive a positive 0.25% update. CMS also finalized a 0.12% decrease to maintain budget neutrality, which has decreased the final conversion factor from the proposed conversion factor.

    In addition, the temporary 2.5% conversion factor increase Congress provided for 2026 expires on December 31, 2026. As a result, both 2027 conversion factors are lower than their 2026 levels.

    Addressing these unsustainable cuts remains one of ASHA’s top advocacy priorities, with current legislation moving through Congress. Join ASHA in urging your members of Congress to address recurring Medicare payment reductions by supporting these vital pieces of legislation.

    Take Action on Medicare Rates

    Other Statutory Payment Adjustments

    In addition to fee schedule changes, Medicare payments are subject to statutory reductions applied outside the fee schedule amounts shown above:

    • Sequestration: The mandatory 2% federal spending reduction continues to apply to Medicare fee-for-service claims.
    • Statutory Pay-As-You-Go (PAYGO): Legislation that increases the federal deficit could trigger an additional reduction of up to 4%, although this has not been confirmed.

    Changes to Practice Expense Methodology

    Practice expense (PE) RVUs reflect resources needed to provide a service, including clinical labor, equipment, supplies, and overhead such as rent and administrative costs. In 2027, CMS is changing how it allocates indirect practice expenses and phasing out older specialty cost adjustments. These changes affect the PE value assigned to services and, in turn, their Medicare payment.

    ASHA is concerned that the revised allocation disadvantages services provided by audiologists and SLPs and opposed these changes in our comments to the proposed rule. Audiologists and SLPs often have little or no separate clinical support staff in their direct expense inputs but still incur overhead. ASHA’s review indicates that many existing audiology and speech-language pathology codes will have nonfacility PE RVU reductions of approximately 5%. That percentage applies to the PE component, not the service’s total RVUs or total payment.

    Starting in 2027, CMS will generally limit annual changes in PE RVUs to 5% through a stabilization policy that phases in larger changes. This does not cap the change in total payment. The policy excludes new, revised, or revalued codes, including the new audiology and speech-language pathology treatment codes. CMS did not extend this protection to new codes that are replacing existing codes.

    Several existing audiology and speech-language pathology codes have reductions large enough to trigger stabilization. The policy delays part of the reduction rather than eliminating it. Affected codes may therefore face further PE RVU decreases in 2028 as the remaining changes are phased in. The effect on total payment will also depend on that year’s conversion factor and other policies.

    ASHA opposes changes that unfairly redistribute Medicare payment away from audiology and speech-language pathology services or fail to recognize the actual costs of providing care. We will continue to advocate with CMS to ensure practice expense is calculated accurately and fairly across clinical specialties.

    Specialty-Level Payment Impact

    CMS’ specialty-level analysis estimates a 4% decrease for audiology from RVU changes, largely involving PE RVUs. This is an aggregate specialty estimate, not a forecast for each service or practice. Separately, CMS’ practitioner-level analysis indicates that most audiologists are expected to have total RVU decreases of 2% to 5%, depending on their service mix. Neither figure should be presented as a complete estimate of final payment; the conversion factor, geographic adjustments, practice setting, and other applicable adjustments also matter.

    CMS groups speech-language pathology with physical and occupational therapy in its specialty impact table. The category’s reported 3% increase should not be used as an estimate for SLPs alone. ASHA’s preliminary review indicates many speech-language pathology services may receive lower payment, particularly because of the practice expense changes. The impact will vary by service mix and, for the replacement treatment codes, by clinical focus and treatment time.

    CMS did not provide a separate specialty-level impact estimate for SLPs. Without that estimate, practices must assess changes using their own service mix, treatment patterns, and applicable rates to plan budgets, staffing, and service delivery.

    ASHA Advocacy on Medicare Payment

    Addressing these payment reductions requires both regulatory advocacy with CMS and legislative action by Congress.

    What ASHA is doing: ASHA submitted formal comments urging CMS to adopt accurate code values, reconsider practice expense changes that unfairly reduce audiology and speech-language pathology payments, and provide a separate specialty-level impact analysis for SLPs. ASHA will continue working with CMS to address the negative effects of these regulatory changes on members.

    Regulatory advocacy alone cannot resolve the structural problems behind recurring Medicare Part B payment cuts. ASHA has strongly opposed these reductions since they began in 2021. Annual congressional interventions have provided only temporary relief, leaving providers and the patients they serve vulnerable to continued financial instability without comprehensive reform.

    ASHA also supports the following federal legislation to address Medicare payment challenges:

    • the RECOVER Act (H.R. 8386), which would eliminate the MPPR policy for outpatient therapy services;
    • the Efficiency Adjustment Delay Act (H.R. 7520), which would delay CMS’ efficiency adjustment through 2029;
    • the Provider Reimbursement Stability Act (H.R. 8163), which would modernize Medicare budget neutrality policies, improve practice expense updates, and limit large annual changes to the conversion factor;
    • The Patients First Act (H.R. 9693), which would make all of the changes in H.R. 8163 and reform Medicare value-based payment programs; and
    • the Medicare Patient Choice Act (H.R. 4204), which would allow Medicare beneficiaries to privately contract with audiologists and SLPs.

    What you can do: Contact your members of Congress and ask them to champion ASHA’s Medicare payment priorities. Ask your colleagues and others who rely on access to audiology and speech-language pathology services to join you in taking action.

    Other Medicare Policy Updates

    KX Modifier and Targeted Medical Review Thresholds

    CMS is increasing the 2027 KX modifier threshold to $2,540 for physical therapy and speech-language pathology services, combined.

    The targeted medical review threshold remains at $3,000 under federal law. Beginning in 2028, the threshold will be adjusted annually using the Medicare Economic Index (MEI).

    Learn more about the KX modifier and targeted medical review process.

    Telehealth

    Medicare telehealth coverage depends on two separate decisions:

    • Eligible services: CMS decides which CPT and HCPCS codes are on the Medicare telehealth services list.
    • Eligible providers: Congress decides which clinical specialties, including audiologists and SLPs, may provide Medicare telehealth services.

    Effective January 1, 2026, following extensive ASHA advocacy, CMS permanently added audiology and speech-language pathology CPT codes that had been temporarily covered since 2020 to the Medicare telehealth services list. Despite initially excluding the new speech-language pathology CPT codes from the authorized telehealth services list, ASHA advocacy secured their inclusion effective January 1, 2027.

    Congress has authorized audiologists and SLPs to provide Medicare telehealth services only through December 31, 2027. Further congressional action is needed to preserve this authority beyond 2027.

    What ASHA is doing: ASHA will continue advocating for permanent Medicare telehealth authority for audiologists and SLPs and appropriate coverage of their services.

    What you can do: Ask your members of Congress to support the permanent authorization of audiologists and SLPs to provide Medicare Part B telehealth services.

    Quality Payment Program

    The Quality Payment Program (QPP) is a Medicare program that is transitioning payments for outpatient services away from a fee-for-service system to a system focused on payment based on quality and outcomes. It is comprised of two tracks: Advanced Alternative Payment Models (A-APMs) and the Merit-based Incentive Payment System (MIPS).

    Merit-based Incentive Payment System

    Most audiologists and SLPs remain exempt from reporting under MIPS, though reporting remains available for those meeting eligibility criteria. For performance year 2027/payment year 2029, the payment adjustments remain -9% to +9%. The actual positive payment adjustment may be substantially less than the statutory maximum due to budget neutrality.

    CMS did not add or remove any of the quality measures for audiologists or SLPs for the 2027 performance year.

    However, the following modifications were made to the existing measures below:

    • 130: Documentation of Current Medications in the Medical Record. For electronic clinical quality measure (eCQM) reporting, CMS expanded the conditions qualifying for the acute health crisis exception and updated eligible encounter codes, removing CPT code 99211 and adding CPT code 92622.
    • 134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan. CMS updated the measure to recognize active depression treatment as an alternative to documenting a follow-up plan after a positive screening. CMS also clarified screening guidance for 17-year-olds. For MIPS CQM, Medicare CQM, and Medicare Part B claims reporting, CMS added provisions recognizing a screening already completed by another clinician during the performance period, with documented results and a follow-up plan if positive.
    • 288: Dementia: Education and Support of Caregivers for Patients with Dementia. CMS clarified that the caregivers receiving education and referrals to support resources must not be part of the patient’s licensed care team.
    • 291: Assessment of Cognitive Impairment or Dysfunction for Patients with Parkinson’s Disease. CMS added physical therapy codes to the criteria used to identify eligible encounters.
    • 317: Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented. CMS added physical and occupational therapy codes to the criteria used to identify eligible encounters for all reporting methods.
    • 374: Closing the Referral Loop: Receipt of Specialist Report. CMS added audiology visit codes to the criteria used to identify eligible encounters for all reporting methods. For eCQM reporting, CMS clarified that when multiple referrals share the earliest date and time, receipt of a consultant report for any one of those referrals satisfies the measure.

          Clinicians should review the updated measure specifications for their reporting method to confirm all applicable requirements.

          CMS finalized Measure 523, Age-Related Hearing Loss: Comprehensive Audiometric Evaluation, for MIPS and the Otolaryngology specialty measure set beginning with the 2027 performance year, which affects 2029 payments. It did not add the measure to the audiology specialty measure set, consistent with ASHA’s recommendation. ASHA opposed its inclusion there because the measure applies to clinicians eligible to bill evaluation and management (E/M) codes, which audiologists cannot report under Medicare regulations.

          New Core Measurement Requirement

          CMS finalized changes that will affect how participating audiologists and SLPs select measures beginning in 2027 and report their performance in future years. These changes apply to clinicians required to participate in MIPS, as well as those who choose to opt in. They do not automatically make all audiologists and SLPs subject to MIPS.

          Beginning with the 2027 performance year, clinicians reporting through traditional MIPS or MIPS Value Pathways (MVPs) must report at least one specialty-specific “core measure”. Core measures are existing measures that CMS has identified as addressing essential aspects of care for a specialty, condition, or patient population.

          For audiologists and SLPs eligible for MIPS reporting, this means reviewing your selected measures before beginning 2027 reporting to ensure that at least one applicable core measure is included. It does not mean reporting an additional measure beyond the number otherwise required.

          Several measures within the audiology and/or speech-language pathology measure sets are designated as core measures, including:

          • 134: Screening for Depression and Follow-Up Plan;
          • 155: Falls: Plan of Care;
          • 181: Elder Maltreatment Screen and Follow-Up Plan;
          • 226: Tobacco Use: Screening and Cessation Intervention; and
          • 282: Dementia: Functional Status Assessment.

          Small practices—those with 15 or fewer clinicians—are exempt from the core measure requirement and the related attestation requirement. Other clinicians or groups without an available or applicable core measure may attest to the fact and report another applicable measure in its place. If the attestation is not completed and a core measure is not reported, then the clinician or group would receive a score of zero for the required measure.

          The complete core measure list can be found in Appendix H of the Calendar Year (CY) 2027 Medicare Physician Fee Schedule (MPFS) Final Rule: Quality Payment Program (QPP) Fact Sheet and Policy Comparison Table found at Resource Library - QPP.

          Electronic Prior Authorization Reporting

          The previously finalized Electronic Prior Authorization measure will be an optional/bonus measure for the CY 2027 performance period for the Promoting Interoperability performance category. It will become required starting with the CY 2028 performance period. Its applicability to audiologists and SLPs will depend on whether they must report this category or qualify for an exception.

          Transition Away From Traditional MIPS in 2031

          Traditional MIPS adjusts Medicare payments based on clinicians’ performance across quality, cost, improvement activities, and promoting interoperability, while MIPS Value Pathways (MVPs) offer a more streamlined approach that groups performance measures around specific specialties or clinical conditions.

          CMS will end traditional MIPS reporting beginning with the 2031 performance year, which affects Medicare payments in 2033 (two years later than originally proposed). Clinicians who remain subject to MIPS will generally need to report through an MVP unless they participate through an applicable A-APM.

          Eligible audiologists and SLPs can continue reporting through MIPs through the 2030 performance year. However, the transition raises concerns because available MVPs do not adequately reflect the services audiologists and SLPs provide. Members may eventually face a narrower choice of measures that do not meaningfully capture their clinical work. CMS acknowledges that additional policies and measure development are needed; the options available to these professions in 2031 are not yet clear.

          What ASHA is doing: ASHA will continue to advocate for practical, clinically relevant reporting options for audiologists and SLPs to demonstrate their value, including MVPs and measures that accurately reflect their services and patient populations. ASHA will also provide updated guidance as CMS develops the transition requirements.

          Accountable Care Organizations

          An accountable care organization (ACO), some of which are considered A-APMs, is a network of doctors, hospitals, and other health care professionals who coordinate care to a defined patient population. The main goal is to improve patient outcomes, reduce unnecessary services, and manage health care costs by aligning providers around shared quality and efficiency goals.

          This rule reflects several policies intended to increase ACO participation, improve financial incentives, and simplify reporting. Beginning April 1, 2027, approved ACOs may reduce or eliminate patient cost-sharing for eligible Medicare Part B items and services. This is not a Medicare-wide elimination of coinsurance. It may reduce financial barriers for eligible patients receiving medically necessary audiology and speech-language pathology services through participating providers. Durable medical equipment, prosthetics, orthotics, supplies, and prescription drugs are excluded.

          An ACO must apply to, and be approved by, CMS to enter Part B cost-sharing support arrangements with its ACO participants. To allow ACOs to participate as quickly as possible, CMS will be collecting initial applications in early 2027 to approve eligible ACOs and their ACO participants to begin eliminating or reducing Part B cost sharing for beneficiaries by the second quarter of CY 2027.

          What ASHA is doing: ASHA is developing resources to help audiologists and SLPs discuss these arrangements with ACOs.

          Quality Reporting and Data Submission

          CMS finalized several ASHA-supported changes that make it easier for ACOs to report quality data and participate in value-based payment, including:

          • the extension of existing quality-reporting options;
          • the establishment of electronic clinical quality measures (eCQMs); and
          • alternative pathways for demonstrating electronic health record technology use.

          These changes give ACOs more flexibility in how they report data, reduce reporting challenges for practices using different electronic health record systems, and allow certain specialty practices to be excluded from specific reporting requirements. CMS also took steps toward modernizing electronic reporting but did not finalize a required timeline for transitioning to a new data-sharing system. These policies balance the modernization of quality reporting with the technological realities of smaller practices and organizations. 

          Additional Requests for Information

          In the 2027 proposed rule, CMS sought public input through several requests for information relevant to audiologists and SLPs, including:

          • feedback on intensive lifestyle interventions to slow the progression of Alzheimer's disease, such as early intervention for cognitive decline and the management of hearing loss;
          • community-based palliative care services;
          • the CPT process; and
          • redesigning primary care.

          ASHA responded to these in our comments. Requests for information gather input; they do not, by themselves, change coverage, coding, or payment requirements. Any resulting policy changes would require further action by CMS. Changes are not expected until 2028 at the earliest.

          What Happens Next

          Audiologists and SLPs should prepare now for January 1, 2027. They should confirm each payer’s accepted codes, payment rates, authorization requirements, and transition instructions. They should also review documentation and scheduling workflows with clinical and administrative staff and confirm that electronic health record and billing systems support the new codes.

          To help members prepare for 2027, ASHA will continue updating its Medicare and coding resources as additional guidance becomes available, including publishing finalized payment and RVU tables. Members can also review the new SLP treatment code resources, the short explainer Why Medicare Matters—Even if You Don’t Bill Medicare, and December webinar information.

          For advocacy opportunities, visit ASHA’s Take Action site and sign up for ASHA Headlines to receive the ASHA Advocate in your inbox.

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          Questions? Email reimbursement@asha.org.


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