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SLP Workload & RVU Documentation Tool
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For CMS Committee Review — Adult and Pediatric Speech-Language Pathology Services (CMS-1848-P)
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Purpose
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This workbook documents the full scope of SLP clinical work — across both adult and pediatric caseloads — in a format that maps directly to how CMS values a CPT/G-code. It is designed to support CMS committee review of both the ten new general-population timed SLP codes and the proposed pediatric GSLPP code, by showing how the same time-and-intensity valuation questions apply differently across populations.
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Why both populations are included
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CMS's proposed rule affects adult and pediatric SLP services through related but distinct mechanisms: ten new time-based codes for the general population, and a separate, untimed GSLPP code for pediatric patients, both valued via a crosswalk to CPT 92507. A CMS committee evaluating time-and-intensity data needs to see both populations side by side — pediatric intensity is driven largely by concurrent behavior regulation and caregiver coaching, while adult intensity is often driven by medical complexity, safety-critical judgment (e.g., aspiration risk), and interdisciplinary care coordination. Both are real, both are underrepresented in a straight adult-to-pediatric crosswalk, and both deserve documentation. Pediatric caseload data remains the primary focus of this tool given the GSLPP-specific comment effort; adult data is included as supporting comparative evidence for the broader ten-code valuation.
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A note on private practice
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Private practice clinicians absorb Practice Expense costs directly and individually — insurance eligibility verification, prior authorization, claims submission, denials and appeals, and payer credentialing are not spread across a large institutional billing department the way they are for hospital- or school-employed clinicians. This workbook includes private-practice-specific administrative activities (tagged Practice Expense RVU) so that this overhead is documented and visible, not folded silently into unpaid time.
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A caution on data representativeness
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Data collected during this period may be skewed by the calendar: vacations and semester breaks can mean skilled nursing facilities, outpatient clinics, and university clinics billing Medicare Part B are underrepresented compared to private practice and hospital settings. Use the Practice Setting field below to record your actual setting on every log, and actively seek out colleagues in SNF, outpatient, and university-clinic settings to contribute their own logs — a data set concentrated in one or two settings will not accurately represent the full range of Medicare Part B SLP billing.
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The three RVU components
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Every Medicare-valued code is priced using three components, each geographically adjusted and multiplied by the annual conversion factor:
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• Work RVU (wRVU) — the clinician's own time and intensity: mental effort, clinical judgment, technical skill, and psychological stress/risk involved in furnishing the service.
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• Practice Expense RVU (PE) — the clinic's overhead: staff time, materials, equipment (e.g., AAC devices, instrumentation), space, and administrative/software costs that support delivering the service.
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• Malpractice RVU (MP) — the liability/risk component associated with furnishing the service.
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Note: This tool uses a simplified categorization designed for advocacy narratives and internal documentation. It is not a substitute for the formal RUC/CMS methodology used to set official PE and MP values, which rely on separate, standardized cost-allocation formulas.
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How to use this workbook
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1. Go to the "Weekly Workload Log" tab. Record your Practice Setting at the top using the dropdown provided. Each row is a task/activity, pre-filled with common adult-medical and pediatric SLP examples side by side, tagged by Population (Adult/Pediatric), Service Phase (Pre/Intra/Post-Service), and RVU Category. Edit, delete, or add rows to match your real caseload.
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2. Enter actual hours per task, per day (Monday–Friday), in the input cells. Blank rows are provided in each section for tasks not already listed.
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3. The "Weekly Summary" tab automatically totals hours and calculates percentages by RVU category, service phase, population, and setting — this is the evidence base for committee review.
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4. Use the "Vignette Builder" tab to turn a real (de-identified) case — adult or pediatric — into a short narrative paragraph structured the way CMS's request for comment asks for: typical time and intensity.
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You're ready to use this tool
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Go ahead and use this tool to document your workload, understand your data, and build a clinical vignette to submit to CMS for comment. You can also use ASHA's resources and guidance to prepare your CMS comment, including ASHA's MPFS 2027 Comment Builder: https://ashaa.quorum.us/campaign/mpfs2027commentbuilder/
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A reminder on messaging
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When writing to CMS: defend the total reference time, don't argue for less of it. The goal of this data is to show that the same total time is spent differently — and often more intensively — in both pediatric and medically complex adult caseloads than the reference code (92507) assumed. Avoid any language suggesting sessions should simply be shorter, for either population.
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