Important Advocacy Update for NC SLPs and Audiologists

From the NCSHLA Vice President of Professional and Governmental Affairs

Medicaid Audits

Heightened Medicaid scrutiny tied to the One Big Beautiful Bill Act (OBBBA) has increased the risk of authorization and payment denials, audits, and recoupments for audiology and speech-language pathology services. Documentation deficiencies are a leading cause of these actions.

Resource: ASHA Medicaid Toolkit: Preparing for Potential Audits Audit toolkit link

Autism and ABA Toolkit from CMS

CMS has sent an ABA toolkit to all state Medicaid agencies toolkit PDF

Key takeaways:

• Forty hours of therapy per week is not best practice, as children need time to eat, nap, and play.

• Best practice aligns weekly hours with support level: Level 1: 10 hours, Level 2: 20 hours, Level 3: 30 hours.

SLP Authorization to Diagnose Autism Spectrum Disorder (ASD)

Waitlists for autism diagnosis are long, particularly for children from birth to age 3. Given SLPs’ expertise in evaluating communication disorders, NCSHLA is exploring options that would allow SLPs to diagnose and bill for this service. Illinois recently enacted HB 5225 (Public Act 104-0561), which takes effect January 1, 2028.  Read more from Northwestern University.  Ashley Perkinson is working closely with Professional and Governmental Affairs Committee members.

Four barriers need to be addressed in North Carolina:

• Scope of Practice: The NC Board of Examiners for Speech-Language Pathologists and Audiologists (NCBOESLPA) does not currently include autism evaluation in the SLP scope of practice. This conflicts with ASHA’s position that appropriately trained SLPs are qualified to diagnose ASD. It also differs from existing NC practice at institutions such as UNC’s CIDD, where SLPs administer the ADOS and contribute to diagnostic decisions. Changing the scope of practice will require legislative action.

• Reimbursement: NC Medicaid does not reimburse SLPs for autism evaluations (CPT 96112/96113), even when SLPs routinely perform them as part of interdisciplinary teams.

• Training: The type, level, and frequency of required training must be determined. Illinois is serving as a model.

• Consultation: Discuss potential impacts with the NC psychology and physician groups.

NC State Health Plan

• On January 1, 2028, the State Health Plan will transition from Aetna back to Blue Cross and Blue Shield of NC (BCBS NC).

• NCSHLA’s VP of Professional and Governmental Affairs has contacted the Plan’s HR department. A letter was sent to raise awareness that BCBS NC does not allow billing with POS 03 and 99. If the new contract does not address this, the transition will be very difficult for Plan members.

• NCSHLA will continue to monitor and engage with the Plan’s team.

Interstate Compact

NCBOESLPA has identified a problem with the FBI background check requirement for joining the compact. Updated legislation is needed to change the requirement and its processes, and advocacy will be needed to help resolve the issue. NCBOESLPA’s attorney, NCSHLA’s lobbyist and Professional and Governmental Affairs Committee are working together to try to bridge the gap.

Audiology

• Four new vestibular CPT codes are added: 92513, 92514, 92527, and 92528.

*see NCSHLA Private Practice Committee updates for additional details

Feeding Codes Under Review for 2027

AMA and CMS are reviewing codes 92610 and 92526 for 2027. We will continue to monitor the process and share updates. ASHA’s randomized member survey on these codes closed on November 2, 2026.

SEALs (State Education Advocacy Leaders)

ASHA’s School SLP Office Hours are available, and the revamped ASHA Workload Calculator is now live. To use it:

1. Go to the ASHA Workload Calculator.

2. Select Go to the Workload Calculator in the blue box.

3. Log in with the email and password associated with your ASHA member account.

4. Your data saves automatically as you enter it.

StAMPS (State Advocates for Medicare Policy)

• Telehealth: Teletherapy services have been extended through December 2027.

• Audiologist classification: Efforts are underway to reclassify audiologists as practitioners to support better reimbursement. ENT boards do not support the change, but there is bipartisan support.

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