Comment on CMS-2026-2377-0001
Anonymous AnonymousOtherIndividual
Summary: A pediatric speech therapist provides feedback on the time distribution for pediatric speech therapy sessions, arguing that the proposed 5-50-5 distribution does not accurately reflect the time spent on setup, transitions, breaks, and family coordination. The commenter notes that while the 60-minute total is accurate, the breakdown of direct versus indirect tasks is incorrect based on their professional experience.
Hello, 60 minutes of work is accurate for a pediatric speech therapy session. However, the assumed 5-50-5 distribution is not accurate in a peds population. As a pediatric therapist, Apx 7 minutes is spent per session setting up a therapeutic environment and activity, 5 minutes transitioning a client in/out of the session (kids are slow), and Apx 8-10 minutes spent in break/regulation/unstructured therapy. Apx 20 minutes is spent in direct/structured therapeutic activities, and then another 15-20 minutes is spend training families/coordinating with school based providers/ coordinating with other professions/tailoring materials to client interests - and other indirect but critical client tasks. All of this was encompassed in 92507, but when then, the CMS rate was grossly undervalued for the 60 minutes of work put in by a highly trained speech-language pathologist.