Timed and Untimed Codes Frequently Asked Questions

Can CPT procedure codes for speech-language treatment be billed by units of time?
Are there any timed codes that SLPs can use?
Why can't "complexity" of care be accounted for in the codes?
Are there any guidelines or data available on what constitutes the typical time allowed for a speech-language pathology session?
Why don't SLPs have time units like PT/OT codes?
Occasionally, I must spend an extremely long period of time rendering an evaluation or treatment session. Is there a way to be reimbursed an extra amount in recognition of the inordinate amount of time?
If I spend 20 minutes treating a patient and bill the cognitive therapy CPT code G0515 (each 15 minutes), can I bill two units?
Can I bill an untimed code more than once per day?

Can procedure codes be billed by units of time?

Most speech-language pathology codes do not have time units assigned to them, such as 92507 (speech-language treatment). If no time is noted in the descriptor, each code counts as one session. A complete list of the CPT codes for speech-language pathology services is available in the ASHA Medicare Fee Schedule or the ASHA Model Superbill for Speech-Language Pathology Practice [DOC].

Are there any timed codes that SLPs can use?

Yes. They are:

Evaluation for non-speech generating device (92605, first hour; 92618, each additional 30 minutes)
Evaluation for speech-generating device (92607, first hour; 92608, each additional 30 minutes)
Evaluation of auditory rehabilitation status (92626, first hour; 92627, each additional 30 minutes)
Assessment of aphasia (96105, per hour)
Standardized cognitive performance testing (96125, per hour)
Cognitive skills development (G0515, each 15 minutes)

Why can't "complexity" of care be accounted for in the codes?

If the treatment code (92507) is revised, the development of additional treatment codes that could address complexity of services would be considered at that time. ASHA would have to present evidence that the services are different in terms of the time it takes to perform the service, the level of technical skill, the physical effort, the required mental effort and judgment, and the stress due to the potential risk to the patient.

Are there any guidelines or data available on what constitutes the typical time allowed for a speech-language pathology session?

Determining what might be considered a "typical" for an untimed code is difficult. Ultimately, it will come down to the judgment of the clinician and whether they feel they can make progress with the patient during the evaluation or treatment session, whatever the amount of time may be. However, untimed codes do have any underlying "typical" time associated with each code. These times are derived from surveys of speech-language pathologists that ASHA conducts in conjunction with the American Medical Association. These typical times are located in what's called the Physician Time File, which is publicly available through the Centers for Medicare & Medicaid Services (CMS).

These underlying "typical" times may be used as guidelines. However, there are no hard and fast rules regarding time "minimums" for untimed codes. Ultimately, the decision to bill a code depends on the clinician’s judgement and documentation to support that the time spent with the patient was medically necessary and clinically appropriate for that patient on that day.

Why don't SLPs have time units like the PT/OT codes?

Historically, the physical medicine and rehabilitation procedure codes were assigned time units of 15 minutes while the codes for speech-language pathology were not. Because of the way codes are developed and established, it is difficult to revise descriptors without significant impact to reimbursement.

Occasionally, I must spend an extremely long period of time rendering an evaluation or treatment session. Is there a way to be reimbursed an extra amount in recognition of the inordinate amount of time?

One of the CPT modifiers is -22, added at the end of the CPT code. This modifier denotes a session or procedure that is unusually long. Many payers will increase reimbursement by 25 to 50 percent when this modifier is included, but the claim will be stopped for manual review and you will need to submit additional documentation with your claim to justify the increased services. Be warned that if you submit claims with the -22 modifier too often, the payer may conclude that the long sessions are not "unusual," and cease to honor the modifier.

If I spend 20 minutes treating a patient and bill the cognitive therapy CPT code G0515 (each 15 minutes), can I bill two units?

No. Medicare has established specific minimum and maximum times for 15-minute codes and most payers have adopted this policy. The minimum time for one 15-minute code is 8 minutes. Two units would be a minimum of 15 + 8 minutes = 23 minutes. This rule is extended to multiple units in the following CMS table:

1 unit: 8 minutes to < 23 minutes
2 units: 23 minutes to < 38 minutes
3 units: 38 minutes to < 53 minutes
4 units: 53 minutes to < 68 minutes
5 units: 68 minutes to < 83 minutes
6 units: 83 minutes to < 98 minutes

Can I bill an untimed code more than once per day?

Medicare specifies that evaluation or assessment procedures may be billed only once per discipline, per date of service, per patient (CPT 92521, 92522, 92523, 92524, 92597, 92607, 92611, 92612, 92616). Additionally, treatment codes may be subject to Medicare's Medically Unlikely Edits (MUEs), which specify how many times a code may be billed per date of service. For instance, the MUE for CPT 92507 prevents this code from being billed more than once in a day. Many payers will adopt Medicare policy.