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

The Centers for Medicare & Medicaid Services (CMS) has released its proposed 2027 Medicare Physician Fee Schedule (MPFS). The MPFS affects payment and other Medicare Part B (outpatient) policies for audiologists and speech-language pathologists (SLPs) beginning on January 1, 2027.

The proposal addresses Medicare payment for the new Current Procedural Terminology (CPT®) codes replacing CPT code 92507, new vestibular testing codes, remote monitoring services, and several broader policies that affect payment for all providers paid under the MPFS. These broader proposals include changes to how Medicare calculates practice expenses and updates to the conversion factors-the dollar amounts used to calculate payment rates for each CPT code.

CMS is seeking input on the proposed fee schedule from the public. Organizations, businesses, and the general public can send feedback to CMS via comment letters until September 14, 2026. CMS is expected to issue the final rule in early November.

On This Page

• CPT and HCPCS Coding Updates
• Broader Medicare Payment Policies
• Other Medicare Policy Updates
• What Happens Next
• Resources

CMS proposes Medicare payment for:

• four new CPT codes describing vestibular diagnostic services;
• 10 new CPT codes describing individual speech-language pathology treatment services; and
• a new Health Care Common Procedure Coding System (HCPCS) Level II code, GSLPP, 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 (PE) 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 payment estimates: Most audiologists and SLPs are expected to be paid under CMS' proposed 2027 conversion factor of $32.8409 for clinicians who do not participate in a qualifying alternative payment model. The estimated national payment amounts below use this proposed conversion factor, are not final, 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 will 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 proposes accepting the RUC recommended work values for three of the four codes. However, for the VST add-on code, 92XX6, CMS proposes a work relative value unit (RVU) of 0.35 rather than the RUC-recommended value of 0.48. If finalized, these proposals would reduce the valuation of rotational vestibular services and lower Medicare payment for audiologists who provide these services.

In addition, CMS proposes adding all four new vestibular testing codes to the Medicare audiology services code list. However, none of the codes would 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 summarizes the proposed work, nonfacility practice expense (PE), malpractice (MP), and total relative value units (RVUs) for the four new vestibular codes, along with the estimated national Medicare Part B nonfacility payment amounts. Full code descriptors and additional coding information are available in CMS Proposes Medicare Payment for New Vestibular CPT Codes.

Placeholder CPT	Short Description	Proposed RVUs (Nonfacility)				Estimated National Payment
		Work	PE	MP	Total
92X10	vHIT of lateral semicircular canal function	0.53	0.39	0.01	0.93	$30.54
92X11	vHIT of lateral and vertical semicircular canal function	0.84	0.59	0.01	1.44	$47.29
92XX5	Rotational vestibular assessment by SHA testing	0.92	1.25	0.02	2.19	$71.92
+92XX6	Add-on code for VST when performed with SHA testing	0.35	0.39	0.00	0.74	$24.30

Speech-Language Pathology Coding Updates

CPT Codes for Speech-Language Pathology Treatment Services

Beginning January 1, 2027, CPT code 92507 will be deleted and replaced by 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;
• (combined) speech sound production and language comprehension and expression disorders; and
• voice, upper airway dysfunction, and/or resonance disorders.

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

CMS proposes accepting the RUC-recommended work RVUs and direct practice expense inputs for all 10 new codes without changes. CMS also proposes designating them as "always therapy" services. This means that clinicians must provide these services under a therapy plan of care and report the appropriate therapy modifier, such as the GN modifier, for services provided under a speech-language pathology plan of care.

Because these codes are considered "always therapy" services, CMS also proposes applying the multiple procedure payment reduction (MPPR) policy to the five base codes representing the initial 30 minutes of treatment. As required under federal law, Medicare reduces the practice expense portion of payment when multiple therapy services are provided to the same patient on the same day. The five corresponding add-on codes for each additional 15 minutes would not be subject to MPPR as they are considered "sometimes therapy" codes. See how MPPR works at Calculating Medicare Fee Schedule Rates and Medicare Multiple Procedure Payment Reductions (MPPR) Scenarios for Speech-Language Pathology Services.

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

How Would MPPR Apply to the New Codes?

Under MPPR, Medicare pays the full work and malpractice portions of all eligible therapy services. The practice expense portion is paid in full for the service with the highest practice expense value and reduced by 50% for each additional MPPR-eligible service provided to the same patient on the same day. Under Medicare, MPPR reduces only the practice expense portion of the payment-not the total payment-by 50%.

Scenario 1: 45-minute Language Treatment Session

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

• 92X4X: Initial 30 minutes of language treatment
• +92X5X: 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.

Scenario 2: Speech-Language and Swallowing Treatment on the Same Day

An SLP provides 45 minutes of speech-language treatment and a separate. Later in the day, another SLP within the same practice provides medically necessary swallowing treatment service for 25 minutes to the same patient. The SLPs report:

• 92X6X: Initial 30 minutes of speech-language treatment
• +92X7X: 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 92X6X because it has the higher practice expense value and 50% of the practice expense amount for 92526. The speech-language treatment add-on code would not be reduced.

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.

Proposed Medicare RVUs and Payment Rates for the New Codes

The new coding structure will result in different payment amounts depending on the type and duration of treatment. Some treatment scenarios may be paid less than services currently reported with 92507, while others may be paid more. Meaningful comparisons should be based on the clinical service provided and treatment time-not simply the payment for a single 30-minute base code.

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

Placeholder CPT	Treatment Category and Time	Proposed RVUs (Nonfacility)				Estimated National Payment
		Work	PE	Malpractice	Total
92X0X	Fluency disorders-initial 30 minutes	0.92	0.67	0.01	1.60	$52.55
+92X1X	Fluency disorders-each additional 15 minutes	0.44	0.29	0.01	0.73	$23.97
92X2X	Speech sound production disorders-initial 30 minutes	0.90	1.10	0.01	2.01	$66.01
+92X3X	Speech sound production disorders-each additional 15 minutes	0.44	0.29	0.01	0.73	$23.97
92X4X	Language comprehension and expression disorders-initial 30 minutes	1.00	0.51	0.01	1.52	$49.92
+92X5X	Language comprehension and expression disorders-each additional 15 minutes	0.48	0.22	0.01	0.70	$22.99
92X6X	Combined speech sound production disorder and language disorders-initial 30 minutes	1.00	1.17	0.01	2.18	$71.59
+92X7X	Combined speech sound production disorder and language disorders-each additional 15 minutes	0.50	0.35	0.01	0.85	$27.91
92X8X	Voice, upper airway dysfunction, and/or resonance disorders-initial 30 minutes	0.98	0.68	0.01	1.67	$54.84
+92X9X	Voice, upper airway dysfunction, and/or resonance disorders-each additional 15 minutes	0.48	0.25	0.01	0.73	$23.97

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 will be revised so that the code stands on its own after CPT code 92507 is deleted.

CPT Code	Short Description	Proposed RVUs (Nonfacility)				Estimated National Payment
		Work	PE	MP	Total
92508	Group speech, language, voice, communication, and/or auditory processing disorders for two or more individuals	0.28	0.31	0.01	0.60	$19.71

Proposed Pediatric Speech-Language Pathology G Code

CMS proposes creating GSLPP, a Medicare-specific Health Care Common Procedure Coding System (HCPCS) code for individual speech-language pathology treatment for pediatric patients. Unlike the new CPT codes, GSLPP was developed by CMS outside the AMA CPT code development and valuation process.

CMS states that it developed the code in response to concerns from interested parties that the new CPT code family may not adequately represent pediatric treatment services. However, the proposed rule does not clearly define the population eligible for GSLPP. The main valuation narrative describes the code as applying to the pediatric population "up to age 21," while the telehealth section and valuation table refer to patients up to age 18 or 21. CMS will need to clarify the intended age.

CMS proposes to:

• value GSLPP using the work and direct practice expense values associated with CPT code 92507;
• assign a work RVU of 1.30, based on 60 minutes of personally performed treatment;
• limit reporting to one unit per patient, per day;
• designate the code as an "always therapy" service; and
• apply the MPPR policy.

Although GSLPP would be an untimed code, the proposed valuation assumes 60 minutes of personally performed treatment. CMS is seeking comments on the typical time and intensity required to provide pediatric speech-language pathology services. These comments may impact final code valuation.

ASHA is concerned that the proposed code was evaluated outside the CPT and RUC processes and does not accurately reflect contemporary pediatric speech-language pathology practice. Pediatric services are already represented within the new CPT code family, which distinguishes treatment by clinical focus and duration. Creating a separate, broad, untimed code could:

• undervalue pediatric services provided during longer or more complex treatment sessions;
• rely on outdated practice expense inputs that do not reflect current supplies and equipment;
• use conflicting age limits, creating uncertainty about which patients would qualify;
• create confusion and administrative burden for SLPs and payers; and
• recreate the challenges associated with CPT code 92507, including difficulty distinguishing changes in clinical practice and patient need from unexplained growth in utilization.

The table below summarizes the proposed work, practice expense, malpractice, and total RVUs for GSLPP, along with the estimated national Medicare Part B nonfacility payment.

HCPCS Code	Short Description	Proposed RVUs (Nonfacility)				Estimated National Payment
		Work	PE	MP	Total
GSLPP	Individual pediatric speech-language pathology treatment	1.30	0.71	0.01	2.02	$66.34

Remote Therapeutic Monitoring Services

CMS proposes several changes to strengthen oversight of remote therapeutic monitoring (RTM) services, which SLPs may bill but have not widely used. The proposals would:

• limit RTM to established patients;
• require an in-person or telehealth visit to initiate services;
• restrict the use of contracted clinical staff to provide RTM services; and
• reduce the practice expense values for several RTM codes.

CMS is also seeking comments on four bundled Medicare-specific G codes for remote monitoring, although implementation is not proposed for 2027.

ASHA supports safeguards to ensure that RTM services are medically necessary, appropriately provided, and accurately valued. A 2024 HHS Office of Inspector General review found that remote monitoring use increased substantially and that 43% of Medicare beneficiaries receiving these services did not receive all required components, underscoring the need for stronger oversight. Because overvaluation or improper billing can affect payment for other services, CMS should address these concerns. However, additional G codes could create unnecessary administrative burden and confusion. ASHA will encourage CMS to strengthen program integrity using the simplest coding approach possible.

Caregiver Training Services

CMS is seeking comments on whether the resources required to provide direct-care caregiver training services are appropriately recognized through HCPCS codes G0541, G0542 and G0543, or whether those resource costs are already included in payment for other Medicare services, such as evaluation and management (E/M) visits. However, specific payment or coding changes were not proposed for any caregiver training services in 2027. These G codes took effect in 2025 and describe caregiver training in direct-care strategies intended to support patients with ongoing conditions and reduce complications.

Importantly, this request for comment does not apply to CPT codes 97550, 97551, and 97552, which ASHA helped develop and which took effect in 2024. Those CPT codes describe caregiver training focused on improving a patient's functional performance in areas such as communication, swallowing, feeding, problem solving, and safety. Although both code sets describe skilled caregiver training provided without the patient present, they address different clinical purposes.

ASHA supports continued separate payment for medically necessary caregiver training when it requires dedicated clinical work and is not duplicative of another billed service. SLPs cannot bill E/M codes under the Medicare program, so treating caregiver training as already included in an E/M visit would not allow SLPs to be reimbursed for direct-care caregiver training services. ASHA will urge CMS to retain appropriate coding and payment for the G codes and to clarify documentation and billing expectations rather than assuming that these services are included in payment for other care.

Input on the CPT Coding and Valuation Process

CMS is also seeking public input on the broader CPT coding and valuation process. The agency raises questions about the AMA's ownership and licensing of CPT, the roles of specialty societies and the RUC, potential conflicts of interest, and whether alternative coding or valuation systems should be considered. CMS also asks whether procedural services could be reported through other systems or grouped into broader payment categories.

This is a request for information only. Any substantive changes would require further policy development and implementation in future years.

ASHA agrees that the CPT and valuation processes can be improved, particularly through greater transparency, stronger data, and safeguards against conflicts of interest. However, replacing the current structure would require substantial financial resources as well as clinical, technical, and administrative infrastructure. CPT is deeply embedded throughout the health care system, including coverage policies, claims processing, contracts, clinical documentation, data collection, and payment systems. Major changes could be extraordinarily disruptive if not carefully designed and implemented.

Any alternative must preserve a meaningful role for qualified health care professionals. Moving too quickly to dismantle the existing process without an equally inclusive replacement could give audiologists and SLPs less influence over how their services are described and valued.

ASHA Advocacy on Coding Issues

Coding changes can have significant implications for clinical workflows, documentation, payment, and patient access. ASHA's advocacy focuses on ensuring that coding and valuation policies reflect clinical practice, support appropriate payment, and are implemented in ways that minimize disruption and unintended barriers to care.

What ASHA is doing: ASHA will:

• urge CMS to adopt the RUC-recommended work value for 92XX6 and finalize appropriate payment policies for the new speech-language pathology codes;
• oppose GSLPP;
• support continued separate payment for medically necessary caregiver training;
• recommend safeguards for RTM services that do not create unnecessary coding complexity; and
• emphasize that any changes to the CPT and valuation process must preserve meaningful participation by qualified health care professionals.

What you can do: Any interested individual, business, or organization can submit comments on Medicare proposed payment policies. ASHA encourages members to review the proposals and consider how they could affect their practice, patients, and service delivery. At the same time, comments should recognize that service delivery models, patient populations, treatment needs, and practice settings vary across the professions. Considering both your own experience and the potential effects on other audiologists and SLPs can help CMS understand the full range of implications. ASHA will provide advocacy resources, including potential talking points and other opportunities to engage in the advocacy process in the coming weeks. Please sign up for ASHA Headlines and monitor ASHA Now to stay involved and learn more.

Medicare payment for individual services depends on more than the value assigned to a specific CPT code or HCPCS code. Final payment rates also reflect the annual conversion factor, changes to the methodology CMS uses to calculate practice expense, and other statutory and regulatory adjustments that apply across the MPFS. These broad policies can increase or decrease payment even when CMS accepts the recommended work and practice expense values for a new or revised CPT code.

Conversion Factors

Every year, CMS updates the conversion factor, which helps calculate MPFS payment rates. Federal law establishes separate conversion factors for clinicians who qualify for certain advanced alternative payment models (APMs) and those who do not. CMS proposes the following conversion factors for 2027.

Participation Status	Proposed Conversion Factor ($)	Change from 2026 (%)
Qualified APM Participants	$33.1693	-1.19%
Clinicians Not in a Qualified APM	$32.8409	-1.68%

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

The proposed amounts reflect several adjustments required under current law. Qualifying APM participants receive a positive 0.75% statutory update, while other clinicians receive a positive 0.25% update. CMS also estimates a 0.53% increase to maintain budget neutrality for proposed changes in work RVUs.

However, these increases do not fully offset the expiration of the temporary 2.5% conversion factor increase Congress provided for 2026. As a result, both proposed 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 support these vital pieces of legislation.

Other Statutory Payment Adjustments

Medicare payments are also subject to statutory reductions applied outside of the fee schedule in addition to the regulatory modifications CMS has undertaken and proposes to adopt in future years. For example, a 2% sequestration reduction-a mandatory federal spending cut-continues to apply to Medicare fee-for-service claims. Statutory Pay-As-You-Go, or PAYGO, rules could trigger an additional reduction of up to 4% when legislation increases the federal deficit, although that is not yet confirmed.

Proposed Changes to Practice Expense Methodology

Practice expense accounts for clinical labor, equipment, administrative costs, office expenses, and other resources needed to provide a service. CMS proposes changing how it calculates the practice expense portion of Medicare payment, including phasing out older specialty cost adjustments and revising how indirect expenses are distributed among services.

Although CMS intends to create a more consistent and data-driven approach, the proposed changes would shift payment among specialties and services. CMS specifically estimates that audiologists would experience payment reductions, in part because of these changes. ASHA's preliminary review indicates that many existing audiology and speech-language pathology services would experience nonfacility practice expense RVU reductions of approximately 5%.

CMS proposes generally limiting annual changes in a code's practice expense RVUs to +/- 5%. However, this protection would not apply to new, revised, or revalued codes, including the new audiology and speech-language pathology codes discussed above.

ASHA will oppose changes that unfairly redistribute Medicare payment away from audiology and speech-language pathology services or fail to recognize the actual costs of providing care.

Specialty-Level Impact of Proposed Changes

CMS estimates that the proposed RVU changes would reduce overall payment for audiology by 3%, largely because of reductions to practice expense RVUs. This specialty-level estimate reflects aggregate changes based on historical Medicare utilization. The actual impact on an individual audiologist or practice will vary based on the services billed, practice setting, geographic adjustments, conversion factor, and other statutory payment adjustments.

CMS does not report speech-language pathology separately. Speech-language pathology services are combined with physical and occupational therapy, making the reported 3% increase for that category an unreliable estimate of the impact on SLPs. Based on ASHA's preliminary review, many speech-language pathology services are also expected to experience payment reductions, particularly because of the proposed practice expense RVU changes.

The lack of a separate speech-language pathology analysis makes it difficult for practices to accurately anticipate annual payment changes and prepare their budgets, staffing, and service delivery. As it has in prior years, ASHA will urge CMS to provide a separate and transparent specialty-level impact analysis for speech-language pathology.

ASHA Advocacy on Medicare Payment

Addressing these proposed payment reductions will require both regulatory advocacy with CMS and legislative action by Congress.

What ASHA is doing: ASHA will submit formal comments urging CMS to adopt accurate code values, reconsider practice expense changes that unfairly reduce payment for audiology and speech-language pathology services, and provide a separate specialty-level impact analysis for SLPs.

However, regulatory advocacy alone cannot resolve the structural problems contributing to recurring Medicare Part B payment cuts that have harmed both Medicare providers and the patients they serve. ASHA has strongly opposed the reductions since they began in 2021, but annual congressional interventions have provided only temporary relief. Without comprehensive reform, Medicare providers will continue to face financial instability.

ASHA also supports federal legislation intended to address the Medicare payment challenges our members face, including:

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.

KX Modifier and Targeted Medical Review Thresholds

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

The targeted medical review threshold will remain at $3,000 per federal law. Beginning in 2028, this threshold will be adjusted annually by 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 factors. CMS determines which services, identified by CPT or HCPCS code, are included on the Medicare telehealth services list. Congress determines which clinical specialties, such as audiologists and SLPs, are eligible to serve as telehealth providers.

Effective January 1, 2026, CMS permanently added audiology and speech-language pathology CPT codes that had been temporarily covered since 2020 to the Medicare telehealth services list, following extensive ASHA advocacy. However, Congress has authorized audiologists and SLPs to provide Medicare telehealth services only through December 31, 2027. Congress will need to act to preserve this authority beyond 2027.

What ASHA is doing: Because several audiology and speech-language pathology codes will change in 2027, ASHA has already contacted CMS to clarify whether the new codes will be included on the authorized telehealth services list. ASHA will also urge CMS through its formal comments to add the appropriate new codes. ASHA will also 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 H.R. 1614 or H.R. 6296, the Advancing Access to Telehealth Act, which would permanently authorize audiologists and SLPs to provide Medicare Part B telehealth services.

Quality Payment Program

ASHA is carefully reviewing proposed changes to the Medicare Quality Payment Program (which includes Advanced APMs and the Merit-based Incentive Payment System [MIPS]). CMS proposes adding Age-Related Hearing Loss: Comprehensive Audiometric Evaluation to the audiology specialty measure set. CMS also proposes ending traditional MIPS reporting beginning with the 2029 performance year and generally requiring participation through MIPS Value Pathways (MVP).

What ASHA is doing: ASHA is reviewing whether the available MVPs include meaningful and practical reporting options for audiologists and SLPs and may comment on any potential gaps, unintended administrative burden, or other negative consequences.

Additional Requests for Information

CMS is seeking public input through several Requests for Information that are 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; and
• the Ambulatory Specialty Model.

ASHA is reviewing these requests and will comment where audiology and speech-language pathology expertise can inform future policies and benefit Medicare patients.

ASHA will submit formal comments to CMS by September 14, 2026, addressing coding, payment, quality, and other policies that affect audiologists and SLPs. CMS is expected to issue the final rule in early November.

ASHA will notify members of targeted advocacy opportunities. Sign up for ASHA Headlines to get the ASHA Advocate in your inbox and visit ASHA Take Action to stay informed and support related federal legislation.

ASHA will continue updating its Medicare and coding resources and providing education to help members prepare for the policies that are finalized for 2027.

ASHA

CMS

Questions? Contact ASHA's health care and education policy team at [email protected].