Telehealth Billing · April 2026

SLP Telehealth Billing After 2025: What Medicare Covers and What It Doesn't

The telehealth landscape for speech-language pathologists has shifted significantly since the Public Health Emergency (PHE) flexibilities expired. If you built a telehealth caseload during 2020–2023, the billing rules you learned then may no longer apply — and billing under expired rules is one of the fastest ways to trigger a post-payment audit.

What Changed After the PHE Ended

During the PHE, CMS temporarily expanded telehealth coverage to include most SLP services, removed geographic restrictions, and allowed patients to receive telehealth services from their homes. Many of those flexibilities were extended through various legislative actions, but the post-2025 landscape looks different:

• Geographic restrictions: CMS guidance indicates that certain geographic requirements for originating sites have been reinstated for some service types, though Congressional extensions have preserved home-based telehealth for many beneficiaries through 2026
• Audio-only services: Audio-only telehealth for SLP services has been significantly restricted — most SLP evaluation and treatment codes now require real-time audio-video interaction
• Place of service codes: The correct POS code depends on where the patient is located and whether the service is synchronous — this is more complex than during the PHE when a blanket POS 02 applied in most cases

Which SLP Codes Are Eligible for Telehealth?

Not all SLP CPT codes are eligible for Medicare telehealth delivery. The current CMS telehealth services list determines which codes can be billed when delivered remotely. As of 2026, the following are generally included:

• 92507 — Speech/language treatment, individual — eligible for telehealth
• 92521–92524 — Evaluation codes — eligible with specific documentation requirements
• 96105, 96125 — Cognitive performance testing — eligibility varies; check the current CMS list

Codes that typically require hands-on or in-person interaction are generally not eligible:

• 92508 — Group treatment — eligibility is limited and state-dependent
• 92610, 92611 — Dysphagia evaluation — generally requires in-person delivery

Place of Service Codes: Getting It Right

The place of service (POS) code on a telehealth claim tells Medicare where the patient was located when the service was delivered. Getting this wrong is one of the most common telehealth billing errors for SLPs:

• POS 02 — Telehealth provided other than in patient's home
• POS 10 — Telehealth provided in patient's home

The distinction matters because reimbursement rates differ. POS 10 (patient at home) typically reimburses at the non-facility rate, while POS 02 may reimburse at the facility rate depending on the code. Using the wrong POS code doesn't just affect your payment — it creates a billing discrepancy that auditors flag.

Modifier Requirements for Telehealth SLP Services

For Medicare telehealth claims, SLPs need to stack modifiers correctly:

• -GN — Required on all SLP services (telehealth or in-person)
• Modifier 95 — Synchronous telemedicine service using real-time audio-video
• -KX — If the patient is above the therapy cap threshold

The modifier stacking order matters: CMS guidance indicates the order should be -GN, -95, -KX when all three are required. Some clearinghouses reject claims with modifiers in the wrong order, generating denials that look like payer rejections.

Documentation Requirements for Telehealth SLP Services

OIG has flagged telehealth documentation as a particular audit focus for therapy services. Best practice suggests your telehealth documentation should include:

• Statement that the service was delivered via telehealth with audio-video technology
• The patient's location (home, clinic, etc.) and the provider's location
• Confirmation that the patient consented to telehealth delivery
• The technology platform used
• Clinical justification for why telehealth delivery was appropriate for this patient and service
• All standard SLP documentation elements (goals, treatment activities, patient response, progress data)

State Medicaid: A Different Set of Rules

If you bill both Medicare and Medicaid, keep in mind that Medicaid telehealth rules vary significantly by state. Some states maintained expanded telehealth flexibilities beyond the PHE, while others reverted to pre-pandemic restrictions. The reimbursement rates, eligible codes, and documentation requirements can all differ from Medicare.