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/

NCCI Edits version 31.2 now in effect. As of July 1, 2025, the National Correct Coding Initiative (NCCI) Edits Version 31.2 is officially in effect and will remain active through September 30, 2025. These edits are critical to ensure proper coding and billing in all outpatient therapy settings for both original Medicare and Medicaid beneficiaries. Whether you’re a provider or a billing professional, staying compliant with the latest NCCI updates is essential for avoiding denials and maintaining proper reimbursement.

National Correct Coding Initiative edits are coding rules published by CMS (Centers for Medicare & Medicaid Services) to:
-Prevent improper payment when incorrect code combinations are billed
-Promote accurate and ethical billing practices
-Ensure services are reported in a standardized, non-duplicative way

These edits include bundled code pairs, mutually exclusive edits, and the need for appropriate modifiers (like Modifier 59 or X-modifiers) when billing certain code combinations together. While CMS has not yet released the detailed summary of changes for Version 31.2 publicly, the quarterly updates typically involve:

-New bundling edits: CPT code pairs that can no longer be billed together unless modifiers are used
-Updated rationale for existing edits
-Revised guidance on modifier usage

Therapists and billing teams must closely review the current NCCI tables and cross reference them with their EMR or billing system to ensure claims submitted during Q3 July 1 to September 30, 2025 comply with the edits. At Physical Therapy Now, our billing and compliance teams stay ahead of these quarterly changes to ensure we deliver not only excellent care but accurate, timely claims submissions.

¨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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