Comment on CMS-2026-2377-0001
Pediatric Speech and Language SpecialistsSupportBusiness
Summary: The commenter, an owner of a pediatric speech-language pathology private practice, supports the creation of the GSLPP HCPCS code but requests clarification on whether the 60-minute work time is a valuation metric or a minimum session requirement. They advocate for clear guidance to ensure that medically necessary sessions of varying lengths (e.g., 30 or 45 minutes) can be billed consistently.
I support CMS’s proposal to create the pediatric HCPCS code GSLPP. As the owner of a pediatric speech-language pathology private practice, I appreciate CMS recognizing that the new timed CPT codes may not accurately reflect the time and complexity of pediatric speech-language treatment.
I respectfully request clarification regarding the proposed “60-minute work time” assigned to GSLPP. Specifically, does the proposed 60-minute work time represent the valuation methodology only (similar to CPT 92507), or is CMS intending to require a minimum 60-minute treatment session in order to report GSLPP?
If GSLPP is intended to replace pediatric CPT 92507, I encourage CMS to explicitly state whether the code may be reported for medically necessary pediatric treatment sessions that are less than 60 minutes. Many pediatric speech-language pathology practices routinely provide medically necessary 30-, 45-, and 60-minute treatment sessions based on each patient’s clinical needs. Without clarification, providers and commercial insurers may interpret the proposed rule differently, resulting in inconsistent implementation and reimbursement.
Clear guidance regarding whether GSLPP is intended to function operationally like CPT 92507 or whether it carries a minimum treatment time requirement would help pediatric practices prepare for implementation and promote consistent billing across Medicare and commercial payers.
Thank you for considering this clarification.