Speech Therapy Code FAQs: What SLPs Need to Know Before January 1, 2027
As summer winds down, we say hello to new school years and new routines. Fall has a way of feeling like a fresh start, and speech-language pathologists (SLPs) are getting one of their own with some of the biggest billing changes they’ve seen in years, starting in 2027.
To help practices get ready, we hosted a live webinar, Unpacking the New Speech Codes, a fireside chat between Rick Gawenda, PT, founder of Gawenda Seminars & Consulting and one of the industry’s most trusted voices on coding and compliance, and Craig Brasington, VP of Revenue Operations here at Stride.
The response was overwhelming. Attendees sent in far more questions than Rick and Craig could get to live. While they worked through as many as they could during the Q&A, we’ve compiled the FAQs below to ensure you get answers to anything you’re still pondering.
Please note: this blog reflects information current as of its publication date. Some key details, including the actual five-digit CPT codes and CMS’s decision on the proposed new G-code, won’t be finalized until later this year.
The New Codes, Timing, and Documentation
What’s changing in 2027?
Effective January 1, 2027, CPT code 92507 is being deleted. In its place, the American Medical Association (AMA) has approved 10 new codes, which will be released in five pairs. Each pair covers a specific type of disorder and includes an “initial 30 minutes” base code and an “each additional 15 minutes” add-on code.
The actual five-digit codes are still placeholders (92X0X, 92X1X, etc.) until the AMA releases the finalized 2027 CPT code set this month, September 2026.
Separately, the description for group therapy code 92508 is being revised to read “Treatment of speech, language, voice, communication, and/or auditory processing disorder; group, two or more individuals.”
Will these codes apply to inpatient and outpatient therapy for adults? Will they apply to Medicare, Medicaid, and third-party payers?
The 10 new CPT codes apply to all outpatient therapy services. As Rick explained, true inpatient acute care is reimbursed under DRG, and skilled nursing Part A is reimbursed under PDPM. CPT codes don’t appear on those claim forms. On the outpatient side, the 10 new codes will apply to all patients 21 years and older, across all outpatient settings and insurances.
For pediatric patients, it depends on whether CMS finalizes the proposed GSLPP code. If it isn’t finalized, pediatric patients will also use the 10 new codes. If it is finalized, each individual payer will decide whether to adopt GSLPP or the 10 new codes for patients up to age 21.
How much time is required to bill these new codes?
To bill one unit of a 30-minute base code, the SLP must spend at least 16 minutes providing the services described by that code (past the midpoint). To bill the associated add-on code (each additional 15 minutes), the SLP must spend at least 38 minutes total providing services described by that pair of codes (The full 30 minutes, plus at least 8 minutes past the midpoint of the 15-minute add-on).
If a patient has two separate disorders, for example, a fluency disorder and a speech sound production disorder, and you want to bill a base code for each, you need at least 16 separate, distinct minutes addressing each disorder individually.
Does the add-on code have to match the base code?
Yes. You can’t mix and match. So, if you do 30 minutes of fluency intervention and 15 minutes of speech sound production intervention, you can’t bill the speech-sound add-on code. To bill an add-on code, you have to complete the full 30 minutes of that same disorder’s base code first, then the additional time addressing that same disorder.
Will we need to document minutes for each specific skill targeted, or can we just address goals in both areas?
Medicare requires documentation of total timed minutes and total treatment time. Rick gave this example: if you spend 30 minutes on an intervention to address speech, sound production, and language comprehension and expression, that falls under one of the new time-based codes. And then if you spend 20 minutes on an untimed intervention like reprogramming an AAC device (CPT 92609), your note should reflect total timed minutes of 30 and total treatment time of 50 (since total treatment time is the sum of timed and untimed services). Other payers would follow similar documentation logic.
Is there a daily limit on how many codes can be billed?
Medicare doesn’t limit the number of units billed per day. Many commercial and Medicaid contracts, however, cap reimbursement at around 4 units per discipline per date of service. Rick noted that this is unlikely to be an issue for SLPs, as a full hour of treatment under a base code plus its add-on code would typically only add up to 3 units (1 unit of the base code, 2 units of the add-on).
Will the GN modifier still apply?
Yes. Both the 10 new codes and the proposed G-code (if finalized) are considered “always therapy” codes under Medicare, which means the GN modifier is required on the claim form, in addition to any other required modifiers for that date of service.
How will MPPR (the Multiple Procedure Payment Reduction policy) be applied?
MPPR will apply to the five 30-minute base codes, but not to the five each-additional-15-minutes add-on codes. All 10 codes will count toward the annual therapy dollar threshold.
Are 92508 and 92526 affected by the deletion of 92507?
92508 isn’t being deleted; its description is being revised. 92526 (treatment of swallowing dysfunction/oral function) is staying as-is; it is not being deleted or replaced.
Can the new codes be billed on the same day as swallowing codes (92526)? And why is the language comprehension/expression code reimbursed so much lower than the others?
Currently, Medicare pays 92507 and 92526 on the same date of service, and many commercial and Medicaid payers do as well. Rick said he expects that to continue for the new codes, but the final answer depends on the NCCI edits version 33.0, which CMS will release around December 1, 2026, for dates of service January 1 through March 31, 2027. That’s when we’ll know for certain.
As for reimbursement, every CPT code’s payment is built from a work relative value unit (RVU) (accounting for the therapist’s stress, effort, judgment, and skill), a practice expense RVU (accounting for support staff, equipment, utilities, rent, etc.), and a malpractice RVU. The language comprehension and expression code pays less because its practice expense RVU is lower. It simply requires less in the way of equipment and supplies to treat those disorders compared to something like speech sound production.
Can an SLP bill the new codes on the same day as ABA codes 97153 or 97155?
No, an SLP cannot bill one or more of the 10 new codes and 97153 or 97155 on the same date of service. That restriction remains the same as it is today. However, within the same practice, an SLP could bill one or more of the new codes while a separate ABA therapist bills 97153 or 97155 for the same patient on the same day, as long as the payer allows it (this generally holds when billing on a standard 1500 claim form—facility billing on a UB-04 works differently). The restriction applies only when the SLP bills both code types on the same date of service.
Will new POCs (plans of care) need to be created for all patients at the start of the year? For example, if a patient is currently authorized for a 25-minute session, would that need to change to 30 minutes?
Rick doesn’t expect the plan of care itself to be the issue. He sees prior authorization as the bigger unknown. For example, a patient authorized in December for 12 visits of 92507 who has only used 5 of those visits by December 31 will, starting in January, be billed under either GSLPP or the 10 new codes instead of 92507. Whether a given payer will require an updated prior authorization at that point is still unknown. Rick recommends starting now by asking your top 4–6 payers what they plan to do with authorizations and code adoption in January.
How should we bill for cognitive-linguistic therapy? The cognitive codes currently aren't accepted by all insurance plans for SLP, so we've been told to use 92507.
According to Rick, cognitive-linguistic therapy will fall under the 92X4X/92X5X pair, which are the same codes used for language comprehension and expression, once 92507 is deleted. So the same code set that will handle general language treatment will also be where cognitive-linguistic therapy lives, for practices moving off 92507 for this reason.
Did AMA and/or CMS take into consideration that 92507 is used differently in schools and outpatient settings?
For the 10 new codes, AMA reviewed the surveys that were submitted to determine the intra-service amount of time for each CPT code. Unfortunately, the number of surveys submitted for each of the 10 new codes was very low, as most SLPs did not complete the survey.
Does the timed code include prep and documentation time? For example, could we have a 30-minute session and 10 minutes of prep and documentation?
The timed codes include the direct one-on-one time with the patient. Any prep time and documentation time away from the patient, while not providing therapy, would not count toward billable time.
How will we code if a primary insurer adopts the new codes but a secondary insurer uses the pediatric code (or vice versa)?
Unfortunately, we will have to wait to see what is finalized. If GSLPP is finalized, insurers other than original Medicare will not be mandated to adopt GSLPP. If a primary insurer adopts GSLPP and the secondary does not, it could create an issue with the secondary insurer paying their responsibility.
What key phrases will insurance reviewers (including AI) be looking for to deny? What key phrases (or terminology) should absolutely be included in documentation?
My recommendation would be to use language in the documentation that supports the CPT code(s) being billed. For example, if you’re billing the speech sound production code, what are you treating the patient for? Use those words in your documentation.
Many of our AAC users also have goals working on speech, specifically motor speech. We currently cannot bill for both of these procedures in the same session. Will we be permitted to combine the new speech/motor speech procedure code and the AAC procedure code 92609 in the same session?
CMS will release NCCI Edits Version 33.0 in early December 2026, effective for dates of service January 1 – March 31, 2027. At that time, we will know the edits and the new codes.
The Proposed G-Code (GSLPP)
What is the proposed G-code, and when will CMS decide whether to adopt it or not?
GSLPP is specifically for pediatric patients up to age 21. If finalized, it would be untimed, billed once per day, and would carry the same description as 92507 with “for the pediatric population up to age 21” added. Because this code would move through the CMS process rather than the AMA process, it would only apply to pediatric patients on Medicare. No other payer, including state Medicaid programs, TRICARE, or commercial insurers, would be required to adopt it.
The decision on the G-code will come out in the final rule. CMS’s final rule typically comes out on or around November 1. Since November 1 falls on a Sunday this year, Rick expects the rule could be released as early as October 30 (last year it came out October 31) or during the week of November 2.
Does GSLPP replace all five new codes for pediatric patients, or would it work alongside them? What about commercial payers?
It depends on payer adoption. If CMS finalizes GSLPP, it becomes an alternative to the 10 new codes for pediatric patients up to age 21. Each individual payer (state Medicaid, commercial insurers, etc.) will decide whether they want to adopt GSLPP or the 10 new codes for that population. It isn’t a case of both applying at once; it’s a per-payer choice between the two systems.
If your practice only treats adults, this doesn’t apply to you at all. GSLPP would only ever cover pediatric patients. For practices with a mix of commercial payers, expect a split. Rick used the example of a practice taking 5 commercial plans, where it’s entirely possible that two adopt GSLPP while the other three stick with the 10 new codes—meaning practices will need to track which code set applies per payer.
How should practices think about session length under the G-code?
Session length should be driven by what the patient needs and can tolerate. That said, there’s a real financial difference to plan around.
GSLPP would be untimed and paid at a flat rate regardless of whether a session runs 20, 30, 40, 50, or 60 minutes. Based on the proposed Medicare payment figures, practices seeing pediatric patients for 40–45 minutes or a full hour would likely come out ahead billing the new base-plus-add-on codes, while practices running shorter 20–30 minute sessions would likely see a better financial outcome from the flat-rate G-code. Practices with per-visit-rate contracts (rather than rates tied to a percentage of Medicare) also have a better shot at preserving their current rate either way.
Rick’s recommendation: start collecting data now on what your SLPs are actually treating and how long those sessions run, so you can model which approach works best for your practice once the rates and the G-code decision are finalized.
Technology, Advocacy, and What to Do Next
Is there software to support benefits verification, including the new code set, in January?
Craig noted this is genuinely hard to answer right now since the actual codes and how each payer will treat them haven’t been defined yet. Technology exists today to handle benefits verification through digital requests for information that flow directly back into a practice’s system. Once the new codes are finalized and payers determine how they’ll handle benefit verification for them, that information can be incorporated.
If your practice bills state Medicaid, Blue Cross, Aetna, Cigna, or other payers, how should you think about what they'll pay?
Rick’s advice is to look at your current contracts for 92507. If a payer pays you a percentage of what Medicare pays for 92507, you can use the proposed Medicare figures to ballpark what they might pay for the new codes. If you can’t figure out how a payer currently arrives at your 92507 rate, it will be much harder to estimate what they’ll pay in 2027. We also won’t know how commercial and Medicaid payers plan to handle these changes until CMS finalizes its rule (expected around November 1) and individual payers respond.
What can we say to CMS to help change the proposed RVU values?
Rick was candid that this is an uphill battle. ASHA has a template letter available that can be a useful starting point. Then, personalize it. Introduce your practice, where you’re located, and the types of patients you serve, rather than sending a generic form letter. Rick also noted that data is what CMS needs to see, not just anecdotal statements about the quality of care being provided.
What should practices financially prepare for during the transition?
Rick recommends having cash on hand for the first couple of months of 2027, since state Medicaid programs and commercial payers are sometimes slow to update their fee schedules and systems. It’s also possible that some payers continue using 92507 for a short period into 2027 even though they’re technically required to use current-year CPT codes.
