Medicare Issues 2026 Proposed Payment Policies for Outpatient Services

July 22, 2025

The Centers for Medicare & Medicaid Services (CMS) has released the 2026 Medicare Physician Fee Schedule (MPFS) proposed rule. This annual rule determines how health care providers, including audiologists and speech-language pathologists (SLPs), will be paid for services they provide to Medicare Part B (outpatient) patients.

The proposed changes for 2026 include several significant policy shifts, some of which could result in payment reductions, while others expand access and flexibility for service delivery, particularly via telehealth. ASHA is closely reviewing all elements of the proposed rule and is working with CMS, Congress, and allied professional organizations to advocate for reforms that support fair reimbursement and safeguard access to care.

The Top Line

2026 Medicare Payment Updates and Budget Impacts

  • The conversion factor (CF) is expected to rise by over 3% in 2026 due to statutory payment updates.
  • However, this increase will likely be negated by budget control mechanisms and cost-reduction measures, including:
    • An “efficiency adjustment” proposed by CMS that could reduce the value of CPT codes for many clinical specialties—including audiologists and SLPs—which ASHA opposes.
    • A reduction in facility-based service payments.
    • Congressionally-mandated budget control mechanisms including sequestration (-2%) and PAYGO (-4%)
  • ASHA urges Congress to reform the Medicare Part B payment system, advocating for annual inflation-based adjustments to avoid payment cuts.

Telehealth Coverage Developments

  • ASHA supports CMS’ proposal to make permanent the telehealth coverage of CPT codes used by audiologists and SLPs, contingent on finalized changes to the request process.
    • This reflects over a decade of advocacy by ASHA.
  • New for calendar year (CY) 2026: Auditory osseointegrated sound processor services (92622, 92623) are added to the telehealth services list.
  • While coverage beyond 2025 is possible, Congress must act to ensure audiologists and SLPs remain eligible telehealth providers.

Other CMS Policy Notes

  • No updates were provided on the audiology access policy (AB modifier).
  • New hearing device service codes were added to the Medicare fee schedule, but:
    • These services remain statutorily noncovered by Medicare.
    • Private payers, including Medicare Advantage and Medicaid, may choose to adopt these new codes.

The following information highlights key provisions impacting audiologists and SLPs, what ASHA Advocacy is doing or has done, and what ASHA members can do.

Payment Rates

Conversion Factor

Every year, CMS updates the conversion factor (CF), which helps calculate MPFS payment rates. Based on the requirements of the Medicare Access and CHIP Reauthorization Act (MACRA), CMS will implement two CFs in 2026:

  1. One for clinicians who participate in qualified alternative payment models (APMs).
  2. One for clinicians who do not participate in a qualified APM.

Participants in a qualifying APM will be eligible for a 0.75% annual payment adjustment and those not participating in a qualifying APM will receive a 0.25% annual payment adjustment. Most audiologists and SLPs do not participate in a qualifying APM.

In addition to these updates, H.R. 1—known as the One Big Beautiful Bill Act (OBBBA)—included a one-time 2.5% increase to the CF for 2026. When this increase is combined with the increases applied based on APM participation and a 0.55% budget neutrality adjustment, it results in an overall proposed payment increase for 2026.

  Total Payment Update (%)  CF Update ($)
Qualified APM Participant 3.83% $33.59
Clinicians Not in a Qualified APM 3.62%

$33.42

However, these increases are likely to be reduced by other Medicare cuts (due to laws that control federal spending), such as:

  • Sequestration: a 2% reduction in Medicare payment.
  • PAYGO (Pay-As-You-Go): a 4% reduction.

Although these specific cuts aren’t addressed in the MPFS, they could result in a total cut of at least 2% to overall Medicare payments. Additional cuts described below could further reduce payments to clinicians.

Congress has acted each year by passing legislation that reduced or eliminated some of these additional cuts and will need to do so again for 2026 payments.

Next Steps for ASHA: Recurring Medicare Part B payment cuts have harmed both ASHA members and the patients they serve. Since these cuts were first proposed in 2021, ASHA has strongly opposed them. Each year, we've relied on congressional intervention to minimize their impact—but these short-term fixes are not enough. Without comprehensive reform, Medicare providers will continue to face financial instability.

ASHA remains fully committed to advocating for lasting change. We are actively working with Congress, CMS, key policymakers, and allied professional organizations—whose members are also affected—to pursue both immediate and long-term solutions. This includes strong support for H.R. 879, the Medicare Patient Access and Practice Stabilization Act of 2025.

What You Can Do: Contact your members of Congress and ask them to cosponsor H.R. 879, which would provide an annual inflation-based payment update to help stabilize payments under Medicare. Ask your colleagues and friends to join you in supporting this important legislation.

Current Procedural Terminology (CPT®) Code Values

Each CPT code goes through a valuation development and maintenance process managed by the American Medical Association (AMA). ASHA volunteer member experts serve on panels to actively participate in this process. Each CPT code’s values are comprised of three components known as relative value units (RVUs)―work, practice, and malpractice―and Medicare applies a geographic adjustment known as the geographic practice cost indices (GPCIs). CMS proposes several modifications to the RVUs and GPCIs that will impact the value of the audiology and speech-language pathology CPT codes.

Practice Expense

Practice expense (PE) reflects the cost to provide care, such as office rent, supplies, equipment, and personnel wages. CMS has established separate PE values for services provided in nonfacility settings (e.g., office) and facility settings (e.g., skilled nursing facility). Beginning in CY 2026, CMS proposes to reduce the facility PE value and increase the nonfacility PE value for all CPT codes paid under the MPFS to recognize the high costs associated with nonfacility-based services.

Overall, specialties that practice primarily in the nonfacility setting—such as SLPs—will see an increase in PE RVUs as a result of this redistribution. (Under Medicare, facility-based payments for speech-language pathology services are always paid at the nonfacility rate and will not be impacted by this proposed change.) However, this will likely negatively impact the facility-based audiology payments for services paid under the facility-based rate. Note that audiology services provided in outpatient hospital settings are paid under a different system―the Medicare hospital outpatient prospective payment system (OPPS)―and are not subject to these facility-based decreases.

Efficiency Adjustment

CMS is proposing a new 2.5% reduction—referred to as an “efficiency adjustment”—to the work RVUs and intraservice time of certain CPT codes. This adjustment applies to diagnostic tests, radiological procedures, and services where using technology or equipment is a major portion of the procedure. CMS expects that as clinical expertise, workflows, and technology evolve, providers will become more efficient.

However, CMS believes that these improvements have not been accounted for through the AMA’s code valuation process. As a result, some CPT codes used by audiologists and SLPs would be affected by this reduction. This adjustment is conceptually similar to the multiple procedure payment reduction (MPPR) that reduces practice expense RVUs for certain services.

CMS plans to reevaluate and apply the efficiency adjustment every three years for all codes that rely heavily on the use of technology or equipment. This means that codes adjusted in 2026 may be reviewed again and face another adjustment in 2029.

It’s important to note that services where the provider’s time is the primary resource―rather than technology or equipment―will not be subject to the efficiency adjustment. In addition, services on the CMS telehealth list are not affected. For example, CPT codes 92507 (speech, language, voice, communication treatment) and 92557 (comprehensive audiometry) are exempt.

If finalized, CMS estimates that almost all specialties, including audiologists and SLPs, will experience no more than a +1% to -1% change in RVUs as a result of this proposed policy. However, the effect on individual services may be greater over time. Since this proposed change reduces work RVUs, CMS projects that there will be a net increase to the CF as required under budget neutrality provisions.

Please see the table below for examples of the impact of the proposed efficiency adjustment and PE changes.

CPT Codes Related to Speech-Language Pathology Services

CPT Code Code Description Current Total Time Total Time After Proposed Efficiency Adjustment (Min) Current Work RVU Work RVU After Proposed Efficiency Adjustment Expected Payment With 2026 CF (Nonfacility Rate) Payment Rate After Proposed Efficiency Adjustment & PE Changes (Nonfacility Rate) Expected Payment Rate With 2026 CF (Facility Rate) Payment Rate After Proposed Efficiency Adjustment & PE Changes (Facility Rate)
31579 Diagnostic laryngoscopy with stroboscopy 34 33.75 1.88 1.83 $196.84 $195.17 N/A N/A
92611 Motion fluoroscopic evaluation of swallow function by cine or video recording 47 46.25 1.34 1.31 $91.90 $91.57 N/A N/A

CPT Codes Related to Audiology Services

CPT Code Code Description Current Total Time Total Time After Proposed Efficiency Adjustment (Min) Current Work RVU Work RVU After Proposed Efficiency Adjustment Expected Payment With 2026 CF (Nonfacility Rate) Payment Rate After Proposed Efficiency Adjustment & PE Changes (Nonfacility Rate) Expected Payment Rate With 2026 CF (Facility Rate) Payment Rate After Proposed Efficiency Adjustment & PE Changes (Facility Rate)
92517 Vestibular evoked myogenic potential (VEMP) testing, with interpretation and report; cervical (cVEMP) 32 31.5 0.80 0.78 $75.86 $73.86 $41.78 $34.42
92622 Diagnostic analysis, programming, and verification of an auditory osseointegrated sound processor, any type; first 60 minutes 72 70.63 1.25 1.22 $79.20 $75.86 $66.17 $53.47

If implemented, the efficiency adjustment would impose yet another arbitrary payment reduction on audiology and speech-language pathology CPT codes—one not driven by data, but based on the unfounded assumption that the code development process does not account for provider efficiency. ASHA maintains that provider efficiency is already considered during the development and valuation of CPT codes. Therefore, any further reductions based on assumed future efficiency gains are unwarranted and unjustified.

Changes to Malpractice (MP) RVUs and Geographic Practice Cost Indices (GPCIs)

MP RVUs and GPCIs are updated every three years. The next update is due to take effect in CY 2026 and may affect the payment rates for services provided by audiologists and SLPs. A nationwide 1.0 floor for the work GPCI was temporarily extended through September 30, 2025. If Congress does not extend the floor or make it permanent, areas previously benefiting from it may see reductions in work GPCI-related payments in CY 2026.

Next Steps for ASHA: ASHA is analyzing the proposed adjustments to work, PE, and MP RVUs, as well as the GPCIs for individual procedure codes, to determine how the combination of changes to the CF, RVUs, and GPCIs will affect national payment rates for audiology and speech-language pathology services.

We remain extremely concerned that the cumulative impact of multiple arbitrary budget control measures—including the efficiency adjustment, MPPR, sequestration, and PAYGO—alongside the absence of an inflationary index to help providers manage the rising cost of care. Together, these factors create an unsustainable financial environment that may compel providers to limit or discontinue care for Medicare beneficiaries, ultimately jeopardizing patient access to care. ASHA will formally oppose the efficiency adjustment in its comments to CMS.

According to CMS’ regulatory impact analysis (RIA), the proposed 2026 CF update and policy changes are estimated to result in a cumulative payment change of -1% to 1% for audiologists and -2% to -1% for SLPs. However, the actual impact on individual clinicians or practices will vary based on several factors, including the clinician’s geographic location and the specific CPT codes billed.

Coding Updates

Hearing Device Service Codes

Beginning in CY 2026, a new set of 12 CPT codes will replace the long-standing CPT codes 92590-92595 to describe professional services related to hearing devices. These new codes are designed to address the professional services associated with air conduction hearing devices used in the treatment of hearing loss.

The revised code set is structured around the four key stages of hearing device care: candidacy evaluation, hearing aid selection, fitting and verification, and follow-up. It’s important to note that these changes apply solely to CPT codes and do not affect the V codes used under the Healthcare Common Procedure Coding System for the hearing aid devices.

Currently, hearing aids and related audiology services are statutorily excluded from Medicare coverage. As such, the existing codes (92590-92595) are not reimbursed by Medicare and do not have associated RVUs. CMS will maintain this policy and assign a “nonpayable” status to each of the new codes as well.

Since these codes fall outside of the MPFS, audiologists will have continued flexibility to negotiate payment rates directly with commercial payers, employers, or patients. The absence of a Medicare-assigned RVU allows for market-driven payment rates that more accurately reflect the value of professional hearing device services in today’s clinical environment.

Please see the table below for the new CPT codes and their code descriptors. The final CPT code numbers will be released in fall 2025.

New CPT Code CPT Code Descriptor
9X01X Evaluation for hearing aid candidacy, unilateral or bilateral, including review and integration of audiologic function tests, assessment, and interpretation of hearing needs (for example, speech-in-noise, suprathreshold hearing measures) discussion of candidacy results, counseling on treatment options with report, and, when performed, assessment of cognitive and communication status; first 30 minutes
9X02X Evaluation for hearing aid candidacy, unilateral or bilateral, including review and integration of audiologic function tests, assessment, and interpretation of hearing needs (for example, speech-in-noise, suprathreshold hearing measures) discussion of candidacy results, counseling on treatment options with report, and, when performed, assessment of cognitive and communication status; each additional 15 minutes
9X03X Hearing aid selection services, unilateral or bilateral, including review of audiologic function tests and hearing aid candidacy evaluation, assessment of visual and dexterity limitations, and psychosocial factors, establishment of device type, output requirements, signal processing strategies and additional features, discussion of device recommendations with report; first 30 minutes
9X04X Hearing aid selection services, unilateral or bilateral, including review of audiologic function tests and hearing aid candidacy evaluation, assessment of visual and dexterity limitations, and psychosocial factors, establishment of device type, output requirements, signal processing strategies and additional features, discussion of device recommendations with report; each additional 15 minutes
9X07X Hearing aid fitting services, unilateral or bilateral, including device analysis,
programming, verification, counseling, orientation, and training, and, when performed, hearing assistive device, supplemental technology fitting services; first 60 minutes
9X08X Hearing aid fitting services, unilateral or bilateral, including device analysis, programming, verification, counseling, orientation, and training, and, when performed, hearing assistive device, supplemental technology fitting services; each additional 15 minutes
9X09X Hearing aid post-fitting follow-up services, unilateral or bilateral, including confirmation of physical fit, validation of patient benefit and performance, sound quality of device, adjustment(s) (for example, verification, programming adjustment(s), device connection(s), and device training), as indicated, and, when performed, hearing assistive device, supplemental technology fitting services; first 30 minutes
9X10X Hearing aid post-fitting follow-up services, unilateral or bilateral, including confirmation of physical fit, validation of patient benefit and performance, sound quality of device, adjustment(s) (for example, verification, programming adjustment(s), device connection(s), and device training), as indicated, and, when performed, hearing assistive device, supplemental technology fitting services; each additional 15 minutes
9X11X Behavioral verification of amplification including aided thresholds, functional gain, speech in noise, when performed
9X12X Hearing aid measurement, verification with probe-microphone
9X13X Hearing device verification, electroacoustic analysis
9X14X Hearing assistive device, supplemental technology fitting services (for example, personal frequency modulation (FM)/digital modulation (DM) system, remote microphone, alerting devices)

Learn more about the new codes at New Hearing Device Services Codes: Modernizing Audiologic Services.

Next Steps for ASHA: ASHA is working closely with the American Academy of Audiology to develop educational resources to prepare audiologists and payers for the transition to the new codes in January 2026.

Speech-Language-Pathology Service Codes

There are no new or revised procedure codes directly related to speech-language pathology services for 2026. However, SLPs may be interested in new codes describing remote therapeutic monitoring (RTM) services, described below.

Remote Therapeutic Monitoring (RTM)

Beginning January 1, 2026, a new set of CPT codes will go into effect to describe RTM services delivered under specific thresholds. These new codes will apply to RTM services provided for less than 16 days of data transmission per 30-day period and less than 20 minutes of interactive communication per month.

In addition, existing CPT codes 98976, 98977, and 98978 have been revised to specify the required minimum of 16-30 days of data transmission per 30-day period.

SLPs may begin reporting these new and revised codes to describe RTM services starting in January 2026. Audiologists are not eligible to bill RTM service to Medicare, but other payers may allow it. Learn more about billing and coding for RTM and other virtual services.

Please see the table below for the new CPT codes and their code descriptors. The final CPT code numbers will be released in fall 2025.

New CPT Code Code Descriptor
98XX4 Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of respiratory system, 2-15 days in a 30-day period
98XX5 Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of musculoskeletal system, 2-15 days in a 30-day period
98XX7 Remote therapeutic monitoring treatment management services, physician or other qualified health care professional time in a calendar month requiring at least 1 real-time interactive communication with the patient or caregiver during the calendar month; first 10 minutes

Telehealth

ASHA Request to Add Services to the Authorized Telehealth List

The structure of Medicare’s telehealth benefit is split between Congress and CMS.

  • Congress determines which clinical specialties (e.g., audiologists, SLPs) are eligible to serve as telehealth providers.
  • CMS determines which specific services (i.e., CPT codes) are covered as telehealth benefits.

CMS has an established process for reviewing public requests to add CPT codes to the authorized telehealth services list on a permanent basis. This process requires submitting a written request by February 10 each year, outlining the codes being requested for addition, and providing supporting research and evidence. CMS reviews these requests and announces its decision in each year’s proposed rule.

In February 2025, ASHA submitted comments [PDF] requesting that CMS permanently add audiology and speech-language pathology CPT codes that have been temporarily authorized telehealth services since March 2021. While audiologists and SLPs may not be authorized telehealth providers in 2026 without congressional action, ASHA continues to advocate for a robust telehealth benefit to ensure continuity of care for Medicare beneficiaries. Establishing a permanent benefit now would allow for easier implementation when these clinicians are granted telehealth eligibility.

As a result of ASHA’s advocacy efforts, CMS is proposing to retain all services currently on the authorized telehealth services list—provided it finalizes a companion proposal to modify the criteria used to evaluate such requests. ASHA supports this change and agrees that the current process for approval is overly confusing, unnecessarily burdensome, and inappropriately restricts access to telehealth services for Medicare beneficiaries.

We will continue to encourage CMS to finalize its proposed reform to the telehealth request process and to permanently cover audiology and speech-language pathology services provided via telehealth.

New Codes for Auditory Osseointegrated Device (AOD) Services Added to Telehealth List

In response to ASHA’s request, CMS is proposing to add the following CPT codes to the Medicare Telehealth Services List:

  • 92622 – Diagnostic analysis, programming, and verification of an auditory osseointegrated sound processor, any type; first 60 minutes
  • 92623 – Diagnostic analysis, programming, and verification of an auditory osseointegrated sound processor, any type; each additional 15 minutes

These additions represent an important step toward expanding telehealth access for individual who rely on AODs.

Next Steps for ASHA: ASHA is committed to achieving permanent authority for audiologists and SLPs to receive payment for services provided via telehealth at parity with payment for in-person services. Our priorities include:

  • Supporting CMS’ proposal to permanently cover the CPT codes used by audiologists and SLPs for telehealth services.
  • Advocating for congressional action to add audiologists and SLPs in law as authorized telehealth providers.
  • Supporting the addition of CPT codes describing services related to auditory osseointegrated sound processors to the telehealth services list.

What You Can Do: Visit ASHA’s Take Action site to urge your members of Congress to advocate for permanent telehealth coverage under Medicare.

Telesupervision of “Incident To” Services

Physical therapists (PTs), occupational therapists (OTs), and SLPs are allowed to provide services “incident to” a physician with direct supervision. “Incident to” coverage policies state that the services of the therapist would be billed under the National Provider Identifier (NPI) of the supervising physician. Traditionally, direct supervision is defined as in the office suite and immediately available to help if needed. However, during the COVID-19 public health emergency, CMS temporarily relaxed this requirement to allow for telesupervision―meaning supervision via real-time audio and visual interactive telecommunications.

Now, CMS is proposing to make telesupervision “incident to” a physician services permanent for PTs, OTs, and SLPs. While ASHA does not believe that a large portion of SLPs provide services “incident to” a physician, we recognized this flexibility is critically important to those who do. In our comments on the 2025 proposed rule and in meetings with CMS staff, we encouraged CMS to permanently extend this flexibility.

Next steps for ASHA: ASHA will support CMS’ proposal for permanent telesupervision of “incident to” services in its comments.

Quality Payment Program (QPP)

The QPP is Medicare’s shift from volume-based fee-for-service payment to a more value-based payment system focused on quality and patient outcomes. The program includes Advanced APMs and the Merit-based Incentive Payment System (MIPS).

Alternative Payment Models (APMs)

APMs are designed to improve the patient experience by encouraging collaboration between providers, improving quality of care, and making services more affordable. APM participants receive payments that reward them for the value of—rather than the volume of—services provided. In this context, value is the outcome of the intervention as related to cost. Accountable Care Organizations (ACOs) are one type of APM that takes system-wide responsibility for the care of an individual across all their health care needs.

Only a small percentage of audiologists and SLPs participate in the APM track. These clinicians typically work for larger health care systems and have the support of finance and administration departments to manage the complexity of such models. Audiologists and SLPs working for organizations participating in APMs can help their organizations earn incentive payments by engaging in quality improvement efforts. The proposed rule includes a mix of flexibilities that could help advance our mutual goals of improving the quality and value of care Medicare beneficiaries receive. But they also might hamper wider APM participation.

Quality Measurement Changes

CMS is proposing to remove the health equity adjustment applied to quality scores beginning in performance year 2025. It also proposes revising the regulations for performance year 2025 and subsequent performance years to rename the “health equity benchmark adjustment” to the “population adjustment,” to more accurately reflect the nature of the adjustment, which accounts for the proportion of the ACO’s assigned beneficiaries who are enrolled in the Medicare Part D low-income subsidy (LIS) or dually eligible for Medicare and Medicaid.

CMS is also proposing to update the APM Performance Pathway (APP) Plus Quality Measure Set to remove measure 487: Screening for Social Drivers of Health. CMS has consistently proposed to remove SDOH measures across the various payment systems it maintains—including home health, inpatient rehabilitation, and skilled nursing—for services provided in 2026.

ACOs are required to administer the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey to meet quality reporting requirements. Currently, survey is conducted using a mail-phone protocol. To help increase response rates, CMS is proposing to adopt a web-mail-phone protocol beginning with performance year 2027 and discontinue the mail-phone protocol for the CAHPS for MIPS Survey.

ASHA remains concerned that removing health equity and SDOH-focused measures may reverse progress toward addressing social barriers to health care access and quality care.

Eligibility and Risk Sharing Changes

In an effort to attract new APM participants, CMS is proposing adjustments to the eligibility requirements for the Medicare Shared Savings Program (MSSP). Under the proposed change, ACOs applying to enter a new agreement period on or after January 1, 2027, must have at least 5,000 assigned beneficiaries in benchmark year (BY) three. They would be allowed to have fewer than 5,000 assigned beneficiaries in BY one, BY two, or both.

This represents a change from previous policy that required an ACO to have at least 5,000 assigned Medicare FFS beneficiaries that are historically assigned to the ACO participants in each of the three historical benchmark years as defined in regulations. The proposed flexibility will help APMs build the infrastructure necessary to effectively participate in the program.

Additionally, CMS is proposing to reduce the length of time an ACO can participate in a one-sided model (no risk of financial loss, only reward) of the BASIC track. Instead of seven years, ACOs would be limited to five performance years during their first agreement period in this track (if eligible). This proposal would be applicable for agreement periods beginning on or after January 1, 2027, and is intended to encourage participation in two-sided risk models, where ACOs can earn rewards but are also accountable for potential financial losses.

Administrative Changes to APM Requirements

If finalized, CMS regulations would require ACOs to report certain changes to their participant list during the performance year, such as when an ACO participant experiences a change of ownership. Similarly, CMS proposes to require ACOs to report changes during the performance year to the ACO’s Skilled Nursing Facility (SNF) affiliate list, such as when a SNF affiliate undergoes a change of ownership.

CMS is also proposing to expand the Extreme and Uncontrollable Circumstances Policies—used to determine ACO quality and financial performance—to include cyberattacks, in addition to natural disasters and public health emergencies.

Learn more about APMs and value-based care on ASHA’s website.

Merit-Based Incentive Payment System (MIPS)

MIPS is one of two tracks under the QPP and focuses on quality improvement in Medicare’s fee-for-service. Audiologists and SLPs became eligible for MIPS for 2019 and will remain eligible in 2026. Clinicians who meet MIPS criteria in 2026 will need to report data associated with 1) quality measures, 2) promoting interoperability, and 3) improvement activities in 2026. This reported data will be used to adjust their payments in 2027.

Because CMS has set exclusions and low-volume thresholds, most audiologists and SLPs will not be required to participate in MIPS for 2025. Additionally, MIPS only applies to clinicians practicing in outpatient, nonfacility settings.

Quality Measures

For the 2026 performance (impacting 2028 payment adjustments), CMS is not proposing any additions to the audiology or speech-language pathology specialty measure set. However, two existing quality measures are proposed for removal:

  • #487: Screening for Social Drivers of Health: Percent of patients 18 years and older screened for food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety.
  • #498: Connection to Community Service Provider: Percent of patients 18 years or older who screen positive for one or more of the following health related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs, or interpersonal safety; and had contact with a Community Service Provider (CSP) for at least one of their HRSNs within 60 days after screening.

CMS is also proposing substantive changes to two measures used in electronic clinical quality measures [eCQM] reporting. Both measures are options for reporting under the designated audiology and speech-language pathology specialty measures sets.

  • #130: Medications in the Medical Record: Percentage of visits for which the eligible clinician attests to documenting a list of current medications using all immediate resources available on the date of the encounter.
    • Proposed Change: To replace the medical reason value set with the Acute Health Crisis Direct Reference Code for the eCQM collection type, as this code better represents the intent of the denominator exception.
  • #134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan: Percentage of patients aged 12 years and older screened for depression on the date of the encounter or up to 14 days prior to the date of the encounter using an age-appropriate standardized depression screening tool AND if positive, a follow-up plan is documented on the date of or up to two days after the date of the qualifying encounter.
    • Proposed Change: A number of revisions to the guidance and numerator for the eCQM collection type to clarify that pharmacological interventions include prescribed or active depression medications. CMS proposes guidance for determining the appropriate plan of care in instances where the screening tool doesn’t adequately establish a diagnosis of depression, and how to address multiple screening results.

Promoting Interoperability

CMS is not proposing substantive changes to this performance category for the 2026 performance/2028 payment year.

Improvement Activities

CMS is proposing two new improvement activities that may be of interest to audiologists and SLPs:

  • Improving Detection of Cognitive Impairment in Primary Care
  • Integrating Oral Health Care in Primary Care

In addition, CMS plans to remove the Achieving Health Equity (AHE) subcategory and replace it with a newly defined Advancing Health and Wellness (AHW) subcategory, reflecting a braoder approach to supporting patient well-being.

MIPS Value Pathways (MVPs)

CMS continues to focus on the transition from MIPS to MIPS Value Pathways (MVPs) by proposing new MVPs related to diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery. CMS reiterates its intention to transition from MIPS to MVPs by performance year 2029/payment year 2031.

ASHA members can participate in MVPs only as members of larger health care systems but not as individuals or as private practices. The current MVP structure does not allow for effective nonphysician participation. Given this limitation, ASHA has repeatedly urged CMS to introduce modifications or flexibilities that would enable access and prevent nonphysician clinicians from being excluded from effective participation in the QPP.

Request for Information

CMS is also issuing a Request for Information (RFI) seeking input on a variety of topics—including well-being and nutrition measures in QPP. CMS is exploring tools and measures that assess overall health, happiness, and satisfaction in life that could include aspects of emotional well-being, social connections, sense of purpose, and personal fulfillment.

Additional information on MIPS is available on ASHA’s website.

Social Determinants of Health (SDOH)

SDOH describes “conditions in the environments where people are born, live, learn, work, play, worship, and age that affect a wide range of health, functioning, and quality-of-life outcomes and risks” (Healthy People 2030).

CMS is proposing to remove measures related to SDOH from its programs.

Next steps for ASHA: ASHA strongly supports collecting SDOH information and making appropriate referrals to community service providers when these social factors impact their health care experience and outcomes. Gathering this information is critical not only to improving care but also to ensuring payment systems adequately reflect the impact of SDOH on the cost of care.

ASHA will submit comments on CMS’s proposal to removal SDOH-related measures and continue advocating of the integrations of SDOH considerations in quality and payment frameworks.

Learn more about SDOH on ASHA’s website.

Outpatient Therapy Services and KX Modifier Threshold

CMS staff has indicated that this section of the proposed rule was accidentally omitted from the published version. A correction notice, which will include additional therapy-related provisions, is expected to be released separately at a later date. ASHA will provide updates to members once it is available.

What’s Next?

  • ASHA will submit formal comments to CMS by September 12, 2025.
  • CMS will issue the final rule November 2025.
  • The changes will be implemented on January 1, 2026.

ASHA Resources

Questions?

Please contact ASHA’s health care and education policy team at reimbursement@asha.org.


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