Build Your CMS Comment

Build Your CMS Comment

The SPEAK Project
We'll help you turn your experience into a strong CMS comment.

Answer the questions below using details specific to your practice and patients. Whenever possible, include real numbers, actual timeframes, costs, staffing details, etc. For example, “we have 100+ children on our waitlist” instead of “we have a long waitlist.” Complete sentences aren't necessary. Share numbers, examples, bullet points, or rough thoughts, and we'll organize them into a personalized CMS comment for you to review and submit. Your draft will be emailed to you when finished. 🚨 CMS comments are public. Do not include patient names, initials, dates of birth, or other identifying information.
About You & Your Practice

First, tell us a little about yourself and the patients you serve.
Your Name

First NameLast Name
Professional Credentials
Email Address (Please type this in correctly. You will not receive your comment if it is incorrect)
MUST BE A VALID EMAIL ADDRESS.
How many years have you practiced as an SLP?
Practice / Organization Name
City
State
Which best describes your role?
Which populations do you primarily serve?
Which setting best describes where you practice

Other
Approximately how many SLPs work in your practice or organization?
Approximately how many patients do you personally serve in a typical week? Skip if you do not currently treat. (i.e. executive, owner, manager)
An estimate is fine.
Briefly describe the patients you serve and the speech-language pathology services you provide.
Don't worry about complete sentences. You can use phrases, bullets, or rough thoughts. Consider age ranges, clinical needs, treatment areas, payer mix, or anything about your patient population you think CMS should understand. Do not include patient names or identifying information.
Did you or your practice participate in the SPEAK Project Cost Analysis Survey?
The Real Cost of Providing SLP Services

Because you participated in the SPEAK Project Cost Analysis Survey or have access to your practice's data, you can help CMS understand how the national findings compare with the actual financial experience of an individual SLP practice. Estimates are okay. If you don't know a number, you may leave optional questions blank.
Based on your SPEAK Cost Analysis Survey, what is your approximate cost to provide one SLP treatment visit?
If you have this number readily available, enter it here. You do not need to recalculate it for this form. It is on the summary tab in the spreadsheet you submitted.
What are the biggest costs involved in providing speech-language pathology services in your practice?
Don't worry about complete sentences. List whatever comes to mind: clinician salaries and benefits, rent, administrative staff, billing, technology, supplies, insurance, training, or other expenses.
What work happens outside of face-to-face treatment that is necessary to provide care? Be specific with metrics and give examples so that this really sounds like it's coming from you. General statements aren't going to resonate with CMS as much as an actual example and REAL numbers.
Think about documentation, chart review, treatment preparation, caregiver communication or education, care coordination, scheduling, insurance requirements, authorizations, and other work that may not happen during the treatment session.
How Does the National Cost Data Compare to Your Practice?

The SPEAK Project collected cost data from SLP practices across the country to document what it actually costs to provide speech-language pathology services. We want CMS to understand whether these aggregated findings reflect what individual practices are experiencing.
SPEAK PROJECT NATIONAL COST FINDINGS

You were emailed the preliminary findings from the SPEAK Project data collection. Thank you again for participating. Without you, none of this would be possible!

Now compare these national findings with what you see in your own practice. Then, tie it back to how it affects patients, SLPs, families. DO NOT USE THESE FIGURES IN YOUR COMMENT. For example:

The cost to provide treatment is 10% above the national average recorded by the SPEAK Project. This is due to _______ (cost to train therapists, cost of living, etc.).

My practice waitlist of ____ months is nearly identical to the national averages collected in the SPEAK Project.

SLP turnover has been on the rise and is 20% greater than the SPEAK Project data shows. This is due to constant budget cuts which means no raises. This impacts our patients' outcomes in a negative way.

Doing it this way, bolsters your claim (because its based on REAL data), and it further validates the SPEAK Project data that will be submitted to CMS.
How closely do the SPEAK Project aggregated findings reflect the financial realities of your own practice? (choose all that apply)
What about the SPEAK Project findings is consistent, or inconsistent, with what you see in your own practice?
You can use rough thoughts, phrases, numbers, or bullet points. Consider staffing and compensation, benefits, administrative expenses, facility costs, technology, supplies, insurance/billing expenses, non-billable clinical time, or overall cost per visit.
Is there anything about the cost of providing SLP services in your practice that the aggregated SPEAK data may underestimate or not fully capture? If no, leave BLANK!
Consider circumstances specific to your practice, such as clinician recruitment and retention, wages in your area, administrative burden, payer requirements, uncompensated clinical work, facility expenses, rural or geographic challenges, or other costs.
Clinical & Workplace Experience

You do not need access to your organization's financial information to provide CMS with valuable evidence. These questions focus on what you personally experience providing SLP services.
What work do you routinely perform outside of the face-to-face treatment time that is necessary to provide your patients' care? Give specific examples of how you prep, collaborate, and coordinate with families. Use actual minutes, number of patients, and DATA. Don't be general, give specific examples.
Think about treatment planning and preparation, chart review, documentation, caregiver education, care coordination, communication with other professionals, materials/setup, insurance requirements, or other work before or after treatment. Rough thoughts or bullet points are fine.
On average, approximately how many minutes of work do you perform outside of the face-to-face treatment time for a typical treatment visit?
Include work before and after the visit. An estimate is fine.
Which of the following have you personally observed in your current SLP setting?
If you selected any of the issues above, tell us what you have personally observed. Telling actually stories and giving a very personal example is much better than a general statement. Give actual numbers (waitlist numbers, caseload size, NUMBER of unfilled SLP positions, what services specifically did you have to reduce). DATA IS POWERFUL HERE!!
Specific examples are especially helpful. If you know approximate numbers such as caseload size, waitlist length, open positions, or how long patients wait for services, include them. Do not include identifying patient information.
What concerns do you have about patients' ability to access SLP services if reimbursement does not adequately support the cost and work required to provide care? Tell a story about a patient who couldn't access therapy in your current situation and how that will be much worse if cuts occur. Tell a story here; it's much better than a generality.
Tell us what you believe could happen in your setting or community. For example: longer waitlists, fewer available clinicians, fewer practices accepting certain payers, reduced treatment availability, or difficulty maintaining services. Rough thoughts are fine.
Reimbursement for the New Timed SLP Treatment Codes

CMS is proposing payment policies for the new timed SLP treatment codes that will replace CPT 92507 beginning in 2027. Help CMS understand whether the proposed reimbursement adequately reflects the work and resources required to provide SLP services and what inadequate reimbursement could mean for practices, clinicians, and patient access.
How long is a typical individual SLP treatment session in your setting?

Other
Do you believe the proposed reimbursement for the new SLP treatment codes adequately reflects the work and resources required to provide these services?
What should CMS understand about the proposed reimbursement for these services? Tell a story about how this could affect you, your patients. Use actual numbers, use actual data. Make it personal. You do not have to use complete setences.
Think about what it actually takes to provide these services and what could happen if reimbursement is too low. You might mention staffing costs, time spent outside the treatment session, rising operating expenses, recruiting or retaining SLPs, waitlists, reduced services, or patient access. Share your own experience. Rough thoughts, examples, or bullet points are perfect.
The Proposed GSLPP

CMS has proposed a new G-code for certain speech-language pathology services (GSLPP). The questions below will help you explain whether you support the proposal, oppose it, or believe changes are needed before it is finalized.
Which best describes your position on the proposed GSLPP?
Why did you choose that position?
Tell us what you like, dislike, or are concerned about. Rough thoughts, phrases, or bullet points are fine.
Which aspects of the proposed GSLPP do you believe CMS should reconsider or clarify? Select all that apply.
For patients who require longer or more complex treatment visits, what work occurs during the full episode of care that CMS needs to understand?
If CMS finalizes the GSLPP, what is the most important change or clarification you believe CMS should make?
Don't worry about policy language. Tell us what you think needs to change and why. We'll help organize your response.
What Would This Mean in the Real World?

Help CMS understand what inadequate reimbursement could actually mean for your practice, your workplace, and the patients you serve. Estimates and real-world examples are helpful.
If reimbursement does not adequately reflect the cost and work required to provide SLP services, what consequences concern you most? Select all that apply.
What is the ONE real-world consequence you most want CMS to understand? Please be specific and personal here. Tell a story about what this has already caused in your decisions, how you will afford to staff a clinic, expand, or as an SLP, how it has affected your ability to invest, plan for the future financially, etc. The more personal this section is, the more impactful your letter will be.
Complete this thought in your own words: “If reimbursement does not adequately support SLP services, I am concerned that…” Be as specific as you can. If you know numbers (positions, visits, patients, waitlist length, staffing, reimbursement, percentages, etc.) include them. Estimates are okay. Rough thoughts or bullet points are fine. Example: “We already have a 4-month waitlist and can't recruit enough SLPs. Lower reimbursement will make that worse.”
Are there particular patients or communities that you believe would be most affected by reduced access to SLP services? Why? If you have an actual example or metric that supports your claim, it makes it even more personal and believable when CMS reads it.
Consider children, adults, Medicare or Medicaid beneficiaries, rural communities, medically complex patients, patients requiring AAC, patients with significant communication needs, or other populations you serve. Do not include identifying patient information.
Other Issues CMS Should Address

There are additional issues in the proposed rule that may affect SLP services. Select any that are important to you. It's okay to select none.
Are there any other issues you would like addressed in your CMS comment? Select all that apply.
If you selected an issue above, what would you like CMS to understand about it? Telling a story about how this concern is valid makes it even more impactful.
You don't need to know technical policy language. Tell us what concerns you, what you have experienced, or what you believe CMS should consider. Rough thoughts or bullet points are fine.
What Do You Want CMS to Do?

Finally, tell us what you want CMS to change, reconsider, or clarify. You don't need to know the technical policy language. We'll use your selections and your own words to help organize your comment.
Which actions would you like CMS to take? Select all that apply.
If CMS remembers only ONE thing from your comment, what do you want it to be? Remember, tell a story, make it personal to you, how is this affecting your family? Your job? Your patient/caseload? Your ability to do your job? General statements will be less impactful, but real stories are what CMS needs to read.
Say it in your own words. What is the most important thing you want CMS to understand or do? A sentence, a few words, or bullet points are fine.
Is there anything else you want CMS to know that we haven't asked about?
This is your opportunity to add anything else about your patients, your profession, your practice, reimbursement, access to care, or the proposed changes. Rough thoughts are fine. Do not include identifying patient information.
Should be Empty:

Build Your CMS Comment

We'll help you turn your experience into a strong CMS comment.

About You & Your Practice

The Real Cost of Providing SLP Services

How Does the National Cost Data Compare to Your Practice?

Clinical & Workplace Experience

Reimbursement for the New Timed SLP Treatment Codes

The Proposed GSLPP

What Would This Mean in the Real World?

Other Issues CMS Should Address

What Do You Want CMS to Do?