Understanding the CPT® Process: How Codes Are Created and Valued
Audiologists and speech-language pathologists (SLPs) rely on Current Procedural Terminology (CPT®) codes every day to describe the services they provide and get paid for those services. These codes don’t happen automatically. They are developed through a national process involving multiple stakeholders.
This page explains how that process works and how ASHA represents the professions within it.
The Basics
CPT codes are developed and maintained by the American Medical Association (AMA). These codes are used nationwide to describe health care services for billing and payment. ASHA represents audiologists and SLPs in this process to ensure their services are accurately described and valued. ASHA members contribute to this work through clinical expertise, volunteer roles, and surveys.
The Centers for Medicare & Medicaid Services (CMS) makes Medicare payment and coverage decisions. Other payers (Medicaid and commercial insurers) make their own decisions but can be heavily influenced by Medicare’s policies.
Not every stage of the CPT process is public or actionable, and ASHA shares information when it is verified and appropriate for broad member engagement.
What Are CPT Codes?
CPT® codes are a standardized system used across U.S. health care to describe services. They are required under federal law (Health Insurance Portability and Accountability Act, or HIPAA) for reporting health care services in most administrative transactions, including billing and claims processing. CPT codes serve as the shared language between providers, payers, and regulators, ensuring that services are described consistently and understood across the health care system. Without them, services could not be consistently reported or reimbursed.
How the CPT Process Works
The CPT code development and valuation process is a collaborative effort involving the AMA, specialty societies like ASHA, and federal agencies. ASHA participates in this entire process as the recognized professional society representing audiologists and SLPs.
Code Creation
- The AMA convenes expert panels of physicians and qualified health care professionals to maintain and value CPT codes.
- The CPT Editorial Panel reviews and approves changes to CPT codes to ensure they remain accurate, clinically meaningful, and usable across the health care system.
- The Specialty Society Relative Value Scale Update Committee (RUC) makes recommendations to CMS on the resources required to provide clinical services. CMS uses these recommendations to help establish relative value units (RVUs), a key component of how CMS calculates Medicare payment rates.
Payment and Coverage
- CMS makes final decisions about Medicare payment and coverage through the Medicare Physician Fee Schedule.
- Medicaid and commercial payers make independent coverage and payment decisions, though many reference CPT codes and Medicare valuation when establishing their own policies.
Resource: Check out How a CPT Code Becomes a Code [infographic]–a step-by-step visual overview of the CPT code development and valuation process.
How ASHA Participates in the Process
ASHA represents audiologists and SLPs throughout the CPT code development and valuation processes. The AMA recognizes ASHA as the specialty society for these professions. ASHA participates alongside other stakeholders in a system led by the AMA and CMS.
When a need for a new or revised CPT code is identified—by CMS, the AMA, or changes in clinical practice—ASHA engages clinical experts, analyzes practice patterns and evidence, develops and submits code change proposals, collects member data to inform valuation, and represents audiologists and SLPs throughout the CPT, RUC, and CMS processes. This work helps ensure services are accurately described, appropriately valued, and recognized within the health care system.
ASHA does this as one participant within a larger, highly structured process where each stakeholder has clearly defined roles and responsibilities.
ASHA works to ensure ASHA members’ services are properly described and valued by:
- Representing audiologists and SLPs in CPT code development and valuation, including participation in AMA committees such as the Health Care Professionals Advisory Committee (HCPAC);
- Developing and submitting Code Change Applications (CCAs) based on clinical practice, evidence, and expert input;
- Collecting and analyzing data to inform valuation, including conducting representative member surveys on time, intensity, and practice expense;
- Providing clinical expertise and recommendations to the CPT Editorial Panel and the RUC;
- Advocating to CMS by submitting formal comments on Medicare payment policies, including the Medicare Physician Fee Schedule; and
- Communicating verified, publicly available information to members through updates, resources, and guidance.
Why this matters: ASHA represents your profession to ensure your services are accurately described and valued.
What ASHA Does Not Control
It’s equally important to understand the limits of ASHA’s role.
- ASHA does not control if and/or when a CPT code is selected for review. (The AMA or CMS flag codes.)
- ASHA cannot stop the process from happening, but it can provide input.
- ASHA does not make final decisions about CPT code approval or structure. (The AMA CPT Editorial Panel does.)
- ASHA does not determine Medicare payment rates or coverage policy. (CMS does.)
- ASHA cannot control how Medicaid or commercial payers establish coverage or payment. (These payers make their own decisions.)
- ASHA cannot disclose confidential information prior to official public release and follows the rules governing the CPT process.
Why this matters: ASHA advocates for you but does not decide on codes or payment.
How Members Are Involved
ASHA’s work in the CPT process is grounded in clinical expertise and data collected directly from audiologists and SLPs.
ASHA’s Health Care Economics Committee (HCEC)—made up of clinicians with expertise in coding and payment policy—plays a primary role in representing the professions. HCEC volunteer members provide subject matter expertise throughout the CPT and valuation processes, help interpret clinical practice patterns, and present and defend code change proposals and valuation recommendations to the AMA CPT Editorial Panel and the RUC.
In addition to HCEC’s direct involvement, broader member input is essential to this work. ASHA relies on input from across the professions to ensure that services are understood and appropriately valued. Members contribute in several structured ways:
- By participating in valuation surveys that collect data on the time, intensity, complexity, and resources required to provide services—one of the most direct and impactful ways members can contribute to how services are valued;
- By providing input on current clinical practice patterns, service delivery, patient populations, evidence-based treatment approaches, and peer-reviewed research;
- By participating in formal processes such as the AMA Interested Party process or reviewing the AMA’s valuation recommendations to CMS; and
- By submitting comments to the federal government during targeted opportunities where coordinated member input can be most effective.
Why this matters: Your input—especially through surveys—directly affects how your services are valued.
Why You May Not Hear About Every Step of the Process
The CPT process includes multiple stages, many of which are highly technical and governed by strict procedural rules. Not every step is public or designed for broad input, and early stages—such as initial review or agenda placement—do not represent final decisions and may change as stakeholders evaluate additional information.
ASHA also participates in a structured, nationally coordinated process that includes confidentiality requirements set by the AMA. These requirements are not optional—they are part of the rules that allow professional organizations to represent their members within the CPT and valuation system.
ASHA shares information when it is publicly available, confirmed, and relevant for member awareness or action. This approach ensures that members receive accurate, useful information rather than incomplete or evolving details.
Why this matters: The AMA or ASHA share updates when information is confirmed—not while decisions are still evolving or confidential.
Payer Policy Context: Medicare, Medicaid, and Commercial Plans
CMS establishes values for new or revised codes through the Medicare Physician Fee Schedule. While Medicare provides a national framework, Medicaid agencies and commercial payers make their own decisions about whether and how to adopt CPT codes, as well as their coverage and payment policies. For example, Medicaid programs may adopt new codes on different timelines and set payment rates based on state budgets.
Medicare policy also has a broader influence across the health care system. Many payers use CPT code structure and Medicare valuation—such as relative value units (RVUs)—as a reference when developing their own payment approaches.
Multiple factors influence final payment decisions, including:
- Medicare budget neutrality requirements;
- Overall health care funding constraints;
- State Medicaid oversight; and
- Payer-specific policies.
ASHA reviews Medicare proposals, advocates for fair payment, and shares guidance with members on what changes may mean for them.
Why this matters: Payment and coverage decisions can vary widely depending on the payer—even for the same service—but payers often look to Medicare’s decisions as a starting point.
How the Pieces Fit Together
The CPT process involves many stakeholders, each with a distinct role. The AMA owns and manages the CPT code set. Specialty societies like ASHA represent clinicians. Advisory groups recommend how services should be valued. CMS makes final Medicare payment decisions. Other payers then decide how to apply those codes and payments in their own systems.
CPT Coding and Valuation Process: Who Does What
|
Entity / Group |
Role |
What They Do |
|
American Medical Association (AMA) |
Owns the CPT code system |
Oversees the CPT process and convenes committees that develop and value codes |
|
CPT Editorial Panel |
Maintains CPT codes |
Reviews and approves new and revised codes to reflect current clinical practice |
|
Relative Value Scale Update Committee (RUC) |
Advises on value of services |
Recommends the time, effort, and resources needed to provide services, which CMS uses to help set payment values |
|
RUC Health Care Professionals Advisory Committee (HCPAC) |
Represents nonphysician providers |
Provides input on valuation for services delivered by professionals such as audiologists and SLPs |
|
Physicians and Other Qualified Health Care Professionals |
Provide care |
Share clinical expertise through specialty societies and surveys that inform code development and valuation |
|
Specialty Societies (e.g., ASHA) |
Represent clinicians |
Organize clinical input, submit code proposals and valuation recommendations, and advocate for the professions |
|
Centers for Medicare & Medicaid Services (CMS) |
Determines payment and regulates federal health care |
Sets Medicare payment rates and policies through the Medicare Physician Fee Schedule |
|
Medicare Physician Fee Schedule (MPFS) |
Serves as Medicare payment system |
Establishes how much Medicare pays for services each year |
|
Medicaid and Commercial Payers |
Determine coverage and payment |
Decide whether and how to cover and pay for services, often using CPT codes and Medicare as a reference |
Why this matters: Each organization plays a specific role, and together they determine how your services are coded and paid.
Additional Resources
Questions? Email reimbursement@asha.org.
