Understanding the Impact on Inpatient and Residential Settings for Treatment Codes Replacing 92507

Beginning January 1, 2027, new timed CPT® treatment codes replace 92507. For details about the new treatment categories, code structure, and time requirements, SLPs can visit ASHA’s New Speech-Language Pathology Treatment Codes Replacing 92507.

To successfully transition to the new code set, clinicians and administrators need a shared understanding of how their organization uses CPT codes and how payers compensate and reimburse facilities and clinicians for the services they provide.

Payers often use different payment methods for inpatient and outpatient care. For example, Medicare Part A, used for facility-based or inpatient billing, generally pays a facility one bundled amount for an inpatient stay rather than paying separately for each CPT-coded service. In outpatient care, CPT codes are more often billed individually, so the usual code selection, time, and documentation rules apply. Receiving care in a facility does not necessarily mean it is billed as inpatient care.

This page gives SLPs a practical starting point by breaking down the difference between payer billing and internal tracking, explaining bundled billing, and providing other important information about inpatient payment.

Internal Tracking vs. Billing

Facilities use different processes to record speech-language pathology services. Depending on the facility, SLPs may select a code themselves, document a service that generates a charge, or have someone else assign the charge. Administrators may also pull information from scheduling, documentation, and/or charge records to track workload and productivity.

In many inpatient settings, CPT codes support documentation and internal tracking rather than individual billing. Accurate coding and documentation remain important, especially when a patient moves from inpatient to outpatient services.

Bundled Billing

While outpatient clinics and private practices bill CPT codes individually, most inpatient facilities operate under bundled payment systems. Medicare refers to these as prospective payment systems, but other payers may use different terminology:

Acute-care hospitals are paid primarily through lump-sum Diagnosis-Related Groups (MS-DRGs).
Inpatient rehabilitation facilities (IRFs) are paid via prospective case-mix groups.
Skilled nursing facilities (SNFs) under Part A are paid under the Patient Driven Payment Model (PDPM) daily rate.
Home health agencies (HHAs) under Part A are paid under the Patient Driven Groupings Model (PDGM) episodic rate.

In a bundled payment, medically necessary services—including speech-language pathology services—are included in a broad, lump-sum facility payment. This does not remove requirements for medically necessary care, accurate documentation, or applicable reporting.

These examples describe traditional Medicare; other payers and contracts, such as Medicaid and private payers, may differ.

Setting/Benefit	What This Means for Speech-Language Pathology Services
Acute-Care Hospital: Covered Part A Stay	Speech-language pathology services are generally included in the hospital’s inpatient payment, not paid separately by individual CPT codes. Internal charge-capture systems may still need to be updated to reflect the new codes.
Inpatient Rehabilitation Facility or Unit: Covered Part A Stay	Speech-language pathology services are included in the rehabilitation facility’s payment. New CPT code time intervals do not replace setting-specific therapy requirements such as the “three-hour rule.”
SNF: Covered Part A Stay	Speech-language pathology services are bundled under the Patient Driven Payment Model (PDPM). CPT codes do not determine payment. Required therapy-minute reporting and internal productivity tracking are processes independent of billing.
SNF: Part B Therapy	When therapy is covered under Part B rather than a covered Part A stay, the SNF bills individual CPT codes for the services provided. Applicable code selection, time, documentation, and payer rules matter even though the patient lives in a facility.
Hospital-Based Outpatient Department	Medicare outpatient speech-language pathology services are generally billed fee-for-service through the Medicare Physician Fee Schedule using CPT codes.

Impact on Productivity or RVU Expectations

The new CPT codes may affect performance metrics if an SLP’s facility or department uses CPT codes or Relative Value Units (RVUs) to measure productivity and patient care. SLPs should keep in mind that CMS values are built for outpatient reimbursement. They do not define inpatient productivity and do not account for the unique time, resources, and medical needs of inpatients. ASHA does not recommend that facilities adopt outpatient billing values as default inpatient productivity benchmarks.

ASHA encourages productivity measures to include all required patient-care activities such as documentation, record review, care coordination, and team meetings, with reasonable labor practices. SLPs will want to work with the facility to establish consistent criteria to determine how services are captured and any clinical concerns around service delivery. This is all separate from payment policy.

Questions for Clinicians and Leaders to Resolve Together

Payment: Which services, if any, do we bill individually, and which do we include in a bundled payment?
Internal capture: How will we record codes and minutes, including clinically appropriate short or interrupted sessions?
Productivity: Are we using actual minutes, CPT codes, CMS work/total RVUs, or locally developed weights to determine productivity? How do we recognize necessary work outside of direct treatment time?
Implementation: Who will update systems, establish consistent criteria, train staff, and address clinical concerns associated with the new CPT codes?