Centers for Medicare and Medicaid Services:

We the undersigned licensed speech-language pathologists (SLPs) (and supporters) submit this formal comment pertaining to the CMS 2023 proposed physician fee schedule.  SLPs evaluate and treat the youngest of babies to the oldest of adults and everything in between. We provide habilitative and rehabilitative care to all that need us. If you have a stroke, we will be there helping you. If you have a premature infant, we will be there helping you. We work in schools, nursing homes, private practices, in-homes. Many of us have dedicated 6+ years of higher education years and countless hours  in continuing education training to remain competent and efficacious.  

Yet so many of us have to work two or three jobs to make ends meet. And student debt from those 6+ years of higher education? Some are close to 100k in debt. We have so much student debt, many of us will be retired and still be paying them off.

How could that be???? The answer is sadly familiar to those of us that have been in the field for a while…reducing reimbursement rates and increased productivity/outcome expectations.

Our reimbursement rates get slashed almost every year. In the past 22 years alone rates have plummeted to unmanageable levels.  On average, rates are reduced 4.3-4.4% YEARLY.** While this seems like a small/manageable reduction, over decades this adds up and creates a negative cashflow in a time of significant inflation.  Furthermore, because SLPs have minimal CPT codes that have been “approved” for our services and there are often contractual limitations in multiple CPT codes per session, rate reductions encourage fraudulent billing simply to break even.    

In earlier years, employers were able to provide a living wage for our highly specialized services. But now, some of us are making LESS than we were 22 years ago. Meanwhile, over the same time period we have seen a cumulative inflation rate of 72.1%. We are overworked and underpaid...sadly, a common story in this country now. Therapists are seeing 16-17 clients a DAY (this would mean 30 min appointments to do things like: address cognitive and feeding needs; oftentimes only once a week-- this isn't adequate). 15-20 years ago we would see 7-8 clients rather than 17!

Furthermore, ALL MCOs and private insurance companies look to CMS for guidance on reimbursements for our fields.  In fact, states (like Texas) further reduce rates and Managed Care Organizations (MCOs) even further reduce our reimbursement rates. Until rates are pennies on the dollar.   

We are having a shortage of therapists despite massive numbers of new graduates.  We are seeing a mass exodus from our professions. Our organizations don't discuss this much other than trying to recruit new students. Our services are important when you need us. Our private practices are going to cash pay only because of such low reimbursement rates. This means services are more easily accessible to the wealthy and extremely difficult for others. Our reimbursements MUST reflect our specialties. 

WE NEED HELP, CMS. Members of our professional organization have desperately pleaded with our national and state organizations. However, inquiries are left unanswered.   

Our reimbursements do not reflect the level of expertise we achieve (masters and doctoral degrees). 

This is what we NEED:

1. Some time ago, SLP services moved from timed codes (valuing our time, specialty, and thoroughness) to untimed codes (minimizing the time to spend with a client/patient reducing quality of services). This has significantly and negatively impacted our quality of services, pay scale, and our physical/mental health. ALL other therapy providers remain using timed codes. Furthermore, states and MCOs further reduce rates. Please, mandate ALL states and insurance companies reimburse at least 100% CMS rates. Further reductions are already planned and some codes are even eliminated. Value our MINUTES, just like every other therapy provider.
2. Home health services (with minimal overhead) monopolize our industry now due to increased reimbursement rates in comparison to outpatient facilities (with significant overhead). This is eliminating small businesses and creating an environment of income disparities for many of our therapists.
3. When looking to the future consider that inflation is real. Stop reducing rates and start looking to maintain rates that correlate with inflation.
4. Please consider a taskforce learning about our professions and providing actual guidance, regulation, and caps on the lowest reimbursement rates allowed.
5. Caps on therapeutic services is not only inhumane it is unethical. Reconsider therapeutic caps across the board. Consider reframing the investment in therapeutic services as rehabilitating tax payers to help fund the system and reduce overall assistance over their lifespan. Meaning, those that are able to rehabilitate/habilitate are more likely to be tax generators.
6. Consider national regulations so that states are not able to reduce access to care or reimbursement rates.
7. STOP looking to save a buck when all of our taxes increase yearly! Take care of taxpayers, instead of working us into the ground. THIS is the PERFECT example why our medical system is crumbling at its core. 

 

Here are some of our common CPT codes to expedite your research:

Speech-Language Pathology (SLP)

CPTs: 92507, 92521, 92523, 97129, 92522, 92523, 92524, 92606, 92609, 92610, 92611, 92612, 92508, 92526

We, American-working speech-language pathologists DEMAND fair and equitable reimbursements. We ask that you consider the above information as you weigh the options of reducing our rates, yet again. 
 

Signed, 

American-practicing speech-language pathologists
 

 

**

https://www.cms.gov/medicare/physician-fee-schedule/search?Y=26&T=0&HT=1&CT=3&H1=92506&H2=92507&M=1​

https://www.brookings.edu/wp-content/uploads/2017/08/medicare-pfs-conference-brief-event-summary.pdf 
https://www.cms.gov/newsroom/fact-sheets/medicare-physician-fee-schedule-2003​ 

https://www.cms.gov/newsroom/press-releases/medicare-proposes-2004-physician-fee-schedule-changes​ 

https://www.cms.gov/newsroom/press-releases/cms-announces-proposed-payment-update-and-policy-changes-medicare-physician-fee-schedule​ 

https://slideplayer.com/slide/7044023/​ 

https://www.cms.gov/newsroom/fact-sheets/final-2009-changes-payment-policies-and-rates-under-medicare-physician-fee-schedule

https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-medicare-physician-fee-schedule-proposed-rule

https://www.asco.org/news-initiatives/policy-news-analysis/more-4-conversion-factor-decrease-2023-medicare-physician
https://www.aaos.org/AAOSNow/2017/Oct/Cover/cover01/?ssopc=1