Providing Audiology and Speech-Language Pathology Telehealth Services Under Medicare

Audiologists and speech-language pathologists (SLPs) are currently authorized to provide telehealth services under Medicare Part B (outpatient services paid under the Medicare Physician Fee Schedule) through December 31, 2024. However, the Centers for Medicare & Medicaid Services (CMS) must issue additional regulations to ensure continuous coverage of telehealth services provided by audiologists and SLPs beyond the federal public health emergency (PHE) and the 151-day extension that Congress provided in 2022. The federal PHE ended May 11, 2023, which means that CMS’s current regulations regarding audiology and speech-language pathology telehealth services, including the list of procedure codes, could expire at the end of the 151-day extension on October 10, 2023, even though audiologists and SLPs will remain authorized telehealth providers through 2024. ASHA expects CMS will release its updated guidance in the summer of 2023 to avoid any gaps in coverage. Please continue to check this page as CMS publishes updated guidance to implement the temporary extension of telehealth services through December 31, 2024.

Medicare Part C (Medicare Advantage plans) may also reimburse for telehealth services provided by audiologists and SLPs. Check with the plan directly for coding and billing guidelines.

ASHA and its members participated in extensive advocacy with Medicare to achieve this temporary expansion. ASHA will continue advocating for permanent coverage of telehealth services under Medicare. ASHA members are encouraged to contact your member of Congress and ask them to permanently authorize telehealth services for audiologists and SLPs by cosponsoring H.R. 2168/S. 3193, the Expanded Telehealth Access Act.

Note: ASHA uses the term telepractice. Any reference to telepractice includes telehealth, which is Medicare’s term for the health care services delivered via interactive audio and video telecommunications technology with real-time capability.

On this page:

• What to Know Before You Get Started
• Covered Audiology and Speech-Language Pathology Services
  • Audiology CPT Codes
  • Speech-Language Pathology CPT Codes
• Coding and Billing Guidelines
• Institutional Billing
• Providing Noncovered Audiology and Speech-Language Pathology Services
• How We Got Here and What's Next
• Questions?

What to Know Before You Get Started

The following information is based on the current status of Medicare telehealth coverage of audiology and speech-language pathology services, which CMS implemented to align with a 2022 law that included a 151-day extension of expanded telehealth services following the end of the federal PHE. CMS’s current regulations are set to expire on October 10, 2023, even though audiologists and SLPs will remain authorized telehealth providers through 2024. However, ASHA expects CMS will release its updated guidance in the summer of 2023 to avoid any gaps in coverage. We will continue to monitor CMS guidance and resources to ensure the accuracy of this information and will update this resource as necessary.

Clinical, Ethical, and Legal Considerations

ASHA guidelines state that the use of telehealth must be equivalent to the quality of in-person services and must adhere to the ASHA Code of Ethics, audiology or speech-language pathology scope of practice, state and federal laws, and ASHA policy.

Clinicians must also consider their own skill/experience and the patient’s needs and capabilities before beginning telehealth services. To ensure compliance, you should do the following: 

• Check whether your state allows telehealth by audiologists or SLPs on ASHA’s state-by-state pages.
• Follow best practice and legal requirements for telehealth, including using Health Insurance Portability and Accountability Act (HIPAA)-compliant technology. Learn more through ASHA’s Practice Portal on telepractice, the Center for Connected Health Policy, and the American Telemedicine Association.

Private (Out-of-Pocket) Pay Arrangements

Medicare’s temporary expansion of telehealth services means that audiologists and SLPs may not enter into a private pay arrangement with Medicare beneficiaries for those services that are included on Medicare’s current telehealth list. For codes that are not authorized telehealth services, audiologists and SLPs can continue to accept private payment from Medicare beneficiaries.

Equipment and Security Requirements

Enforcement of HIPAA rules was loosened for Medicare services during the COVID-19 PHE to help clinicians choose telepractice platforms that may not comply with HIPPA privacy and security requirements. However, enforcement has resumed with the expiration of the federal PHE. Resources to help you stay in compliance with privacy and security rules include:

• ASHA’s Practice Portal on Telepractice (see Privacy and Security)
• ASHA’s Overview of HIPAA
• Center for Connected Health Policy
• American Telemedicine Association

Approved Patients and Locations

New and Established Patients

Although Medicare only allows established patients to receive telehealth services, CMS has said it will not conduct audits to ensure that a prior relationship existed during the public health emergency. This means that clinicians may provide telehealth services to both new and established patients. Clinicians should consider state practice acts or other local laws and regulations before beginning services with new patients. Clinicians may be required to evaluate new patients before providing clinical recommendations or treatment.

Location of Patients and Clinicians

Current federal law also removes limitations on where Medicare patients must be located to be eligible for telehealth services. Patients in both rural and urban areas can continue to receive telehealth services through December 31, 2024.

In addition, federal law modifies the definitions of originating site (where the patient is) and distant site (where the clinician is). The patient’s home can serve as an originating site through December 31, 2024. Clinicians can also continue to provide services from their own home or their place of employment (e.g., private practice office, skilled nursing facility).

Patient Consent

The patient must consent to receive services via telehealth at least once annually. You or your administrative staff can obtain verbal consent and notify the patient of applicable co-pay and deductible costs at the same time you provide the service. Be sure to document that you received the verbal or written consent.

Covered Audiology and Speech-Language Pathology Services

Medicare’s telehealth services list outlines approved Medicare Part B services by Current Procedural Terminology (CPT®) code. Clinicians should not use CPT codes on the approved list to submit claims for other telehealth services not included on this list. 

Clinicians must follow Medicare requirements for covered services, whether provided in person or via telehealth. For example, certain audiology services require a physician referral, and speech-language pathology services should include physician certification of the plan of care. Chapter 15 of the Medicare Benefit Policy Manual [PDF] outlines coverage and documentation requirements for Medicare Part B services.

Codes not included on this list may be provided via telehealth to Medicare beneficiaries under a private pay arrangement, with the patient's consent.

Audiology CPT Codes

It's important for audiologists to know how telehealth coverage will change and what options you have to continue Medicare telehealth services once the federally-declared PHE and 151-day extension are over.

During the Coverage Expansion

The following codes represent audiology services covered under the Medicare telehealth benefit through at least October 10, 2023, even though audiologists will remain authorized telehealth providers through 2024. However, ASHA expects CMS will release its updated guidance in the summer of 2023 to avoid any gaps in coverage.

Keep in mind that audiologists can't charge Medicare beneficiaries for these specific services and must bill Medicare directly. If a service isn't on the current authorized telehealth services list, you can enter into a private pay arrangement with the Medicare beneficiary for that specific service (vestibular testing, for example).

After December 31, 2024

Unless Congress provides another temporary or permanent extension of telehealth coverage, Medicare will no longer reimburse audiologists for any telehealth services. Audiologists can enter into private pay arrangements with Medicare beneficiaries to continue providing telehealth services, if the patient agrees.

See also: What to Expect at the End of the PHE

Speech-Language Pathology CPT Codes

It's important for SLPs to know how telehealth coverage will change and what options you have to continue Medicare telehealth services once the federally-declared PHE and 151-day extension are over.

During the Coverage Expansion

The following codes represent speech-language pathology services covered under the Medicare telehealth benefit through at least October 10, 2023, even though SLPs will remain authorized telehealth providers through 2024. However, ASHA expects CMS will release its updated guidance in the summer of 2023 to avoid any gaps in coverage.

As noted in the table below, CMS also allows select speech-language pathology services to be conducted via audio-only in those cases where the patient does not have access to audiovisual equipment. These services may still be reported to Medicare as telehealth services using the appropriate CPT codes and telehealth modifier. 

Keep in mind that SLPs can't charge Medicare beneficiaries for these specific services and must bill Medicare directly. If a service isn't on the temporarily authorized telehealth services list, you can enter into a private pay arrangement with the Medicare beneficiary for that specific service.

After December 31, 2024

Unless Congress provides another temporary or permanent expansion of telehealth coverage, Medicare will no longer reimburse SLPs directly for any telehealth services. SLPs can enter into private pay arrangements with Medicare beneficiaries to continue providing telehealth services, if the patient agrees.

See also: What to Expect at the End of the PHE

Coding and Billing Guidelines

Audiologists and SLPs providing telehealth services should report the same CPT codes and follow the same coding guidelines as they would for in-person services, including same-day billing rules and time requirements. For example, a brief check-in via telecommunication technology should not be reported with an evaluation or treatment CPT code (such as 92507 or 92601) and is not considered a Medicare telehealth service.

Medicare telehealth services are reimbursed at the same rate as in-person services paid under the Medicare Physician Fee Schedule for Part B services.

Place of Service (POS) and Modifiers

Medicare instructs Part B providers who perform telehealth services to report the POS code that reflects the location where in-person services would have been provided. Providers should also append the modifier -95 (synchronous telemedicine service) to each CPT code provided via telehealth. Modifier -95 indicates telehealth services provided in an outpatient nonfacility setting. Providers in outpatient settings should not use POS 02 (telehealth provided in a location other than the patient's home) because this will result in payment at the facility rate. There is also POS code 10, effective January 1, 2022, that reflects telehealth services provided in the patient's home. Although Medicare recognizes POS 10, clinicians providing outpatient services into the patient's home should continue billing for services provided via telehealth as outlined above.

For example, a clinician who provides telehealth services from their own home, but would normally have seen their patients in their private practice, would use POS 11 (office) and include modifier -95 for each CPT code reported.

SLPs should also append the -GN modifier to all CPT codes to indicate services provided under a speech-language pathology plan of care.

Communication Technology-Based Services Versus Telehealth Services

Communication technology-based services (CTBS) are not considered telehealth services under Medicare’s definition. According to Medicare, telehealth services represent services that would normally occur in person. On the other hand, CTBS codes represent brief communication services conducted over different types of technology to help avoid unnecessary office visits and slow the spread of COVID-19. They are virtual, by definition, and do not replace full evaluation and treatment services covered under the Medicare benefit and described by existing CPT codes for telehealth/in-person services. CTBS codes are limited in scope and reflect brief, virtual services such as e-visits or virtual check-ins that require clinical decision-making.

Medicare allows SLPs, but not audiologists, to report CTBS codes, even after the end of the PHE.

Institutional Billing

On May 28, 2020, CMS announced that institutional settings could provide Medicare outpatient therapy services via telehealth and report them on institutional claims, such as the UB-04, with the -95 modifier. However, this applies only to services that can be billed separately from the institutional bundle, are paid under the Medicare Physician Fee Schedule (MPFS), and are included as an authorized service on the Medicare telehealth list.

CMS created significant confusion in the runup to the end of the PHE by stating on two national stakeholder calls that telehealth services could not be reported on the UB-04 claim form after May 11, 2023. After extensive advocacy by ASHA, CMS issued updated guidance [PDF] (see questions 21 and 22) indicating that it would use its “enforcement discretion” to continue to allow facilities to bill for outpatient telehealth services paid under the MPFS through 2023. Specifically, hospital outpatient departments, skilled nursing facilities, rehabilitation agencies, and comprehensive outpatient rehabilitation facilities should continue to bill for telehealth services as they have during the PHE. However, CMS must also provide additional legal and regulatory clarification for facility settings prior to 2024 to avoid interruptions in access to care for Medicare beneficiaries.

CMS provides guidance for specific settings including applicable type of bill (TOB) codes and services, as follows.

• Hospital: Report hospital outpatient therapy services on TOB 12X or 13X. 
• Skilled Nursing Facility (SNF): Report PT, OT, and speech-language pathology services on TOB 22X or 23X only when the patient is not on a Part A stay.
• Critical Access Hospital (CAH): Report PT, OT, and speech-language pathology services on TOB 85X.
• Comprehensive Outpatient Rehabilitation Facility (CORF): Report ambulatory outpatient PT, OT, and speech-language pathology services on TOB 75X.
• Outpatient Rehabilitation Facility (ORF): Report ambulatory outpatient PT, OT, and speech-language pathology services on TOB 74X. 
• Home Health Agency (HHA): Report PT, OT, and speech-language pathology services on TOB 34X to patients in their homes only if those patients are not under a home health plan of care. 

For additional details, see Medicare Allows Institutional Billing for Some Outpatient Telehealth Services During the COVID-19 Pandemic.

Facilities providing services via telecommunications technology as part of the bundled institutional payment, including audiology services paid under the hospital outpatient prospective payment system (OPPS), should follow additional CMS guidance, as outlined below.

Home Health Agencies

Medicare is precluded by federal law from covering telehealth services under the Part A home health benefit. In its home health fact sheet [PDF], CMS states that only in-person services can be reported via the home health claim even when the home health plan of care is developed or updated to include the use of telecommunication technology. As noted above, home health agencies may provide telehealth services to Medicare beneficiaries in their homes, but only when the patient is not under an established Medicare Part A home health plan of care. 

Skilled Nursing Facilities (SNFs)

Part A: CMS pays SNFs through a bundled payment for all covered Part A services. Therapy services that are furnished via telehealth or telecommunications technology would be considered part of the bundled prospective payment system payment under Part A and would not be separately billable for those patients in a Part A covered SNF stay.

Part B: As noted above, Part B services can be reported on the UB-04. However, only select services can be provided via telehealth, as outlined later on this page.

Hospital Outpatient Departments (HOPDs)

In May 2023, CMS issued updated guidance [PDF] (see questions 21 and 22) indicating that it would use its “enforcement discretion” to continue to allow HOPDs to bill for outpatient telehealth services paid under the physician fee schedule through 2023. Specifically, HOPDs should continue to bill for telehealth services as they have during the PHE.

Providing Noncovered Audiology and Speech-Language Pathology Services

Medicare’s temporary coverage of telehealth services means that audiologists and SLPs may no longer enter into a private pay arrangement with Medicare beneficiaries for those services that are now included on Medicare’s telehealth list. Clinicians may continue to accept private payments from Medicare beneficiaries for services not included on the telehealth list. However, if Medicare adds more services to the approved telehealth list, enrolled Medicare providers must reimburse their patients for those services and submit claims to Medicare for payment. Unenrolled providers must also reimburse their patients, but may not submit claims to Medicare for reimbursement and may not enter into private pay agreements with Medicare beneficiaries for covered services.

Informed Consent

Because telehealth services not included on the telehealth list are statutorily excluded from Medicare coverage, clinicians aren’t required to provide an Advance Beneficiary Notice (ABN) [PDF] of financial liability to the Medicare beneficiary. However, an ABN may be given as part of the informed consent necessary for engaging any patient in a private contact to make direct payment for non-covered telehealth services. ASHA also recommends that clinicians clearly inform the Medicare beneficiary, in writing, that Medicare covers audiology and speech-language pathology services provided in-person and have them voluntarily confirm their desire to receive services via telehealth.

Establishing Rates

The Medicare fee schedule does not directly apply to services statutorily excluded from Medicare coverage. ASHA recommends following the Medicare Physician Fee Schedule (MPFS) rates for private pay contracts with Medicare beneficiaries for telehealth services. Medicare reimburses providers at the same rate for both in-person and telehealth services, when covered. ASHA recommends following that precedent. Some adjustments to MPFS rates can be made to accommodate the financial needs of the patient under a written policy that applies to all patients, regardless of form of insurance.

Legal and Regulatory Foundation

Although CMS has temporarily waived certain telehealth laws, allowing audiologists and SLPs to provide some telehealth services during the public health emergency, Section 1834(m) of the Social Security Act (SSA) precisely defines telehealth as a service provided by a physician or practitioner under the Medicare benefit. The SSA currently classifies audiologists and SLPs as suppliers. This means standing Medicare law doesn’t recognize audiologists and SLPs for reimbursement for telehealth services. This statutory exclusion eliminates such services from Medicare service delivery requirements and shifts financial liability for paying for the services to beneficiaries at the discretion of the patient. As a result, audiologists and SLPs may provide non-covered telehealth services to Medicare beneficiaries and enter into private pay contracts to receive reimbursement, if the patient agrees. This interpretation is supported by a series of direct communications with CMS staff, engagement with external experts familiar with Medicare law, and in consultation with other professional associations.

Section 50.3.2 of Chapter 30 of the Medicare Claims Processing Manual [PDF] also makes it clear that when services are statutorily excluded from coverage, Medicare policy does not apply, there is no Medicare reimbursement, and the use of an ABN is voluntary.

It is important to note that the statutory exclusion of certain telehealth services creates this unique exemption from coverage. Audiologist and SLPs cannot opt out of Medicare and must comply with all regulatory requirements when they provide covered services to Medicare beneficiaries, including temporarily covered telehealth services. 

How We Got Here and What's Next

How We Got Here

The expansion of the Medicare telehealth benefit in 2020 was a joint effort of Congress and CMS with input from stakeholders, including ASHA. Congress determines the clinical specialties authorized to bill Medicare for telehealth services and CMS identifies the services, as represented by CPT codes, that are authorized telehealth services. Medicare’s telehealth coverage policies evolved over the course of the federal PHE to include a variety of clinical specialties, practice locations, and covered services. CMS announced the initial telehealth expansion in an April 30, 2020, press release and its COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers [PDF]. The original expansion included a limited set of eligible audiology and speech-language pathology telehealth services. CMS subsequently expanded the list of Current Procedural Terminology (CPT) codes on March 30, 2021, resulting in a more comprehensive list of eligible telehealth services provided by audiologists and SLPs. Medicare Part C (Medicare Advantage plans) may also reimburse for telehealth services provided by audiologists and SLPs. Check with the plan directly for coding and billing guidelines.

The PHE was renewed multiple times since 2020 in compliance with the requirements of federal law and Congress has provided additional legal extensions for telehealth services provided by audiologists and SLPs as it strives to develop a permanent telehealth policy. Prior to the Consolidated Appropriations Act of 2023 (which extended coverage through December 31, 2024), Congress passed a similar law in 2022 that provided coverage for 151 days after the end of the PHE. Each time Congress updates the law, CMS must issue companion regulations implementing the requirements of the law. The importance of implementing regulations became increasingly significant when the Biden Administration announced the end of the PHE would be May 11, 2023. At this time, the regulations align with the 2022 law meaning Medicare telehealth coverage for audiologists and SLPs will last through October 10, 2023. However, it is expected the necessary regulations will be provided in time to avoid a gap in coverage in October.

What's Next

ASHA and its members participated in extensive advocacy with Medicare to achieve this temporary expansion. ASHA will continue advocating for permanent coverage of telehealth services under Medicare. ASHA members are encouraged to contact your member of Congress and ask them to permanently authorize telehealth services for audiologists and SLPs by cosponsoring H.R. 2168/S. 3193, the Expanded Telehealth Access Act.

Questions?

Contact reimbursement@asha.org for additional information. Please continue to monitor this webpage for the latest developments related to Medicare coverage of telehealth services. For more information on telehealth coding and billing across payers is also available on ASHA’s website.

CMS also publishes extensive resources to help clinicians providing telehealth services to Medicare beneficiaries.