The Honorable Chiquita Brooks-LaSure 
Administrator 
Centers for Medicare & Medicaid Services 
U.S. Department of Health and Human Services
Attention: CMS-1807-P
P.O. Box 8016
Baltimore, MD 21244-8016

RE:       Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare Overpayments

Dear Administrator Brooks-LaSure:

The undersigned audiologists and speech-language pathologists (SLPs) who treat Medicare beneficiaries write to offer comments on the Calendar Year (CY) 2025 Medicare Physician Fee Schedule (MPFS) proposed rule. 

We are extremely concerned that the Centers for Medicare & Medicaid Services (CMS) has not added audiology and speech-language pathology services to the authorized telehealth services list—either on a provisional or permanent basis—as part of the proposed rule. We understand that Congress will need to pass legislation extending coverage for telehealth services provided by audiologists and speech-language pathologists (SLPs). However, CMS must have a robust benefit already in place so that when Congress does act, Medicare beneficiaries can maintain access to telehealth services as seamlessly as possible. Therefore, we urge CMS to add the Current Procedural Terminology (CPT®) codes used by audiologists and SLPs to the authorized telehealth services list for 2025. It is critical that we work together to ensure continued access to medically necessary care for all Medicare beneficiaries. 

Audiologists specialize in preventing, evaluating, and treating hearing and balance disorders. SLPs identify, evaluate, and treat speech, language, swallowing, and cognitive impairments. Medicare beneficiaries must have continued access to our medically necessary diagnostic and therapeutic services to meet their functional goals.

CMS implemented a procedure for adding services to the authorized telehealth services list on January 1, 2024 through a robust engagement process, including a public comment opportunity. The finalized procedure included a requirement that stakeholders interested in adding services to this list submit a request that details the services requested and the research and evidence that supports their inclusion by February 10 of each year. These requests would be vetted through specific criteria finalized in the CY 2024 fee schedule rule. Our professional organization, the American Speech-Language-Hearing Association (ASHA), submitted a timely request.

Unfortunately, CMS did not use this procedure for assessing the request submitted by ASHA to include audiology and speech-language pathology services permanently on the authorized telehealth services list. Instead, it proposes that these services cannot be added to the telehealth services list until a “comprehensive analysis” has been performed. We are confused about why the existing approval procedure is insufficient and why a “comprehensive analysis” is required. We are also uncertain as to what a comprehensive analysis will include, which makes it hard to understand what additional information we can provide to CMS to help it determine the long-term viability of our services via telehealth. We respectfully request that CMS use its existing approval procedure and avoid placing additional burden on stakeholders by requiring a comprehensive analysis. 

Moreover, CMS does not appear to address the continued coverage of these codes beyond December 31, 2024. Specifically, in the 2024 proposed rule, CMS states:

“That said, we proposed to keep these therapy services on the Medicare Telehealth Services List until the end of CY 2024. We will consider any further action with regard to these codes in future rulemaking.”

And in the 2024 final rule it states:

“Further, we note that the scope of our proposals did not include coverage status of the codes, merely whether CMS should change the status of the codes on the telehealth list. After consideration of public comments, we are finalizing as proposed. These therapy services will remain on the Medicare Telehealth Services List until the end of CY 2024.”

However, there is no mention of the continued coverage status of audiology and speech-language pathology services in the 2025 proposed rule outside of noting their status is not changed from provisional to permanent. In addition, our services are not included in Table 8 of the proposed rule entitled “Services Proposed for Addition to the Medicare Telehealth Services List for CY 2025.” As a result, we believe that continued telehealth coverage of these codes is in question, even if Congress acts to extend permanent or provisional telehealth authority to audiologists and SLPs. We recommend CMS clearly state that audiology and speech-language pathology services will remain covered on a provisional basis through at least the end of 2025. 

Thank you for the work you have done to improve Medicare coverage and beneficiary access during the pandemic and beyond. We appreciate CMS taking the time to consider our perspective as clinicians who provide critical services to Medicare beneficiaries, the patients who ultimately stand to suffer the most from reduced access to telehealth services. We look forward to your continued efforts on behalf of Medicare enrolled providers and the patients we serve.

Sincerely,