By: Mendi Lancaster, MS, CCC-SLP, TSHA StAMP, and Lisa Milliken, MA, CCC-SLP, FNAP, CDP, RAC-CT, TSHA President

Our Texas Speech-Language-Hearing Association (TSHA) State Advocates of Medicare Policy (StAMP) advocacy works collaboratively with the American Speech-Language-Hearing Association (ASHA) healthcare policy team and lobbyists to support efforts that are important to our members for many state and national hot topics. This includes federal areas related to payment and service delivery such as CPT code reimbursement, telepractice, therapy plan of care, and certification requirements.

Every November, we receive the “Final Rule” from the Centers for Medicare and Medicaid Services (CMS), which establishes payment policies and standards related to many other factors such as for broker payments, prior authorization rules, and updated policies related to rules for a variety of healthcare settings. The most recent CMS Final Rule was released on November 1 and included hundreds of pages of rules and updates for settings such as clinics, home health agencies, inpatient rehab facilities, and skilled nursing facilities.

Following is a quick summary of what to expect and how you can help to join our advocacy efforts:

• This year’s Final Rule, for changes effective January 1, 2025, included the expected 2.8% cut to our therapy CPT codes for Part B (outpatient services), but the cut could be as big as 9% because of multiple budget control mechanisms that Congress controls. (See the action item in the next section to support the Medicare Patient Access and Practice Stabilization Act to fully reverse this 2.8% payment cut.)

To better understand this complicated and ongoing issue, know that CMS uses an annual conversion factor (CF) to calculate Medicare phyisican fee schedule (MPFS) payment rates. For 2025, CMS estimates that the CF will be $32.35, representing a 2.83% decrease from the $33.29 CF for 2024. Although CMS included a 0.02% positive budget neutrality adjustment, the decrease in the CF is mostly due to expiration of the temporary 2.93% positive adjustment that Congress implemented to temporarily mitigate significant payment cuts in 2024.

CMS also provides a Regulatory Impact Analysis (RIA), which estimates cumulative payment changes for providers in addition to the cut to the CF. For 2025, it’s estimated that audiologists and speech-language pathologists (SLPs) will see a cumulative 0% additional change in payments based on policy changes. However, cumulative payment changes experienced by individual clinicians or practices will vary because actual payment depends on several factors, including the clinician’s location and the specific procedure codes billed.

Source: Medicare Issues 2025 Final Payment Policies for Outpatient Services

https://www.asha.org/news/2024/medicare-issues-2025-final-payment-policies-for-outpatient-services/

• As a result of our combined advocacy with ASHA and other states (where Texas SLPs and audiologists led the way), CMS will maintain audiology- and speech-language pathology-related services on the provisionally approved telehealth services list. That means that the CPT codes have miraculously been approved for telehealth services in 2025. But we still need for Congress to pass a law for telehealth services to be allowed for Medicare beneficiaries beyond December 31, 2024. And Medicare Advantage plans may choose if they will allow telehealth without this law or if they will follow the rules of traditional Medicare.
• 2025 updates have been made to the therapy plan of care certification requirements, which could reduce administrative burden for SLPs. These changes provide an exception to the physician/NPP signature requirement on the therapist-established treatment plan for purposes of the initial certification. This exception applies in cases in which the patient’s medical record includes a signed and dated written order or referral from the patient’s physician/NPP and evidence that the therapist has transmitted the treatment plan to the physician/NPP within 30 days of the initial evaluation (e.g., fax confirmation, copies of emails or electronic health record transmission, snail mail delivery confirmations).
• Caregiver training services (CTS) codes now have a policy update that will allow SLPs to obtain a patient’s verbal consent and be reimbursed when provided via telehealth.  This code was approved and effective as of January 1, 2024, for caregivers training to be provided without the client present but was not allowed for telehealth visits. However, the latest update allows this training to be provided without the client via telehealth visits.
• CMS provided no updates regarding the audiology access (“AB modifier”) provision.

How can your voice can be heard to make a difference?

1. Ask your representatives to support the Medicare Patient Access and Practice Stabilization Act  to fully reverse the 2.8% payment cut. 
2. Ask your representatives to make audiologists and SLPs permanent Medicare telehealth provide to ensure your ability to provide telehealth services in 2025. Thanks to your support for this action over the past few months, CMS has allowed the continuation of telehealth SLP and audiology CPT codes. But Congress still needs to act to protect your ability to provide telehealth services. That’s why we’re still advocating for permanent telehealth coverage!