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In an important policy update, the Centers for Medicare & Medicaid Services has revised the Medicare Benefit Policy Manual to clarify and tighten the qualifications for speech language pathologists, delivering outpatient therapy services to Medicare beneficiaries. The change has significant implications for Clinical Fellow SLPs, especially in billing and service delivery across all outpatient settings.
As of April 18, 2025, Centers for Medicare & Medicaid Services has removed language from Section 230.3 of the manual that previously allowed clinical fellows to treat Medicare patients under supervision. The revised language now requires all SLPs billing Medicare outpatient therapy services to fully meet licensure and post graduate experience requirements, effectively disqualifying CFs with provisional licenses from treating Medicare outpatients.

To be recognized as a qualified provider of outpatient speech therapy services under original Medicare, a speech language pathologist must:
– Hold a Master’s or Doctoral degree in speech-language pathology (since Jan 1, 2015)
– Be licensed by the state in which services are provided

In states without licensure:
-Complete 350 supervised clinical hours
-Complete 9 months of supervised, full-time practice post-degree
-Pass a national examination approved by HHS

The American Speech Language Hearing Association is currently in communication with CMS. The American Speech Language Hearing Association is actively advocating for the recognition of provisional licensees as qualified Medicare providers. Their goal is to reverse the policy change and allow CF SLPs to participate in Medicare outpatient services under defined conditions.
This 2025 CMS update brings major implications for staffing, billing, and supervision in outpatient speech therapy. While it enhances clarity on qualifications, it also limits the flexibility of practices employing CFs. At Physical Therapy Now, we remain committed to delivering compliant, high-quality care and supporting our therapists through evolving regulations.

¨If you or someone you know might need physical therapy, please call us at 305-570-1633, or if you are interested in opening a Physical Therapy Franchise. Email us franchise@physicaltherapynow.com or visit our website at https://physicaltherapynow.com/franchise/

As healthcare reimbursement continues to decline and operational costs rise, many organizations are searching for ways to optimize billing and increase revenue per outpatient therapy visit. One question we’ve heard more frequently is: “Can a hospital bill HCPCS code G0463 every time a patient receives outpatient physical, occupational, or speech therapy?” To help clarify this issue, we’re breaking down what G0463 represents, when it can be billed, and why it does not apply to therapy-specific revenue codes. According to the 2025 HCPCS Level II coding manual, G0463 is defined as: “Hospital outpatient clinic visit for assessment and management of a patient.” This code is used by hospitals to report clinic visits where evaluation, treatment planning, and coordination of care occur in a hospital outpatient setting.

Hospitals are allowed to bill G0463 for outpatient clinic visits that involve assessment and management services. These are typically medical or primary care-related appointments, not therapy services. To be valid, G0463 must be paired with a supporting revenue code that aligns with clinic or evaluation-type services. Hospitals should not bill G0463 when a patient attends an outpatient therapy session for physical, occupational, or speech therapy. The revenue codes associated with therapy services (042x, 043x, 044x) are not aligned with the clinic-based evaluation and management services required for billing G0463. Trying to bill G0463 in this context could lead to denials, compliance issues, or audit risk. As hospitals and therapy clinics navigate financial pressures, it’s important to optimize billing within the rules. While G0463 can be a valid code for hospital-based outpatient clinic visits, it does not apply to therapy services billed under the appropriate therapy revenue codes.

¨If you or someone you know might need physical therapy, please call us at 305-570-1633, or if you are interested in opening a Physical Therapy Franchise. Email us franchise@physicaltherapynow.com or visit our website at https://physicaltherapynow.com/franchise/

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