Updated September 2026
Two things have moved since this article was first published. The AMA released the CPT 2027 code set on September 9, 2026, which assigns the official five-digit numbers to the ten new treatment codes. And the CMS comment period on the proposed rule closed on September 14, 2026. The final rule is expected in November 2026, and GSLPP is still a proposal until then.
When CMS released its Medicare Physician Fee Schedule proposed rule in the summer of 2026, it added something almost nobody expected: a proposed new pediatric speech-language pathology code, referred to as GSLPP. It has been passed around as a possible reprieve from the ten new timed codes replacing 92507. Here is the honest read for a pediatric practice.
For most pediatric caseloads, GSLPP changes very little, and the work of preparing for 2027 does not go away. Below is what it is, why it probably will not reach your patients, and what to actually do.
The one-line version
GSLPP is a proposed, untimed, Medicare Part B pediatric code that CMS floated in response to concerns that the ten new timed codes do not fit pediatric sessions. It is not final, and because it lives in Medicare Part B, it will not automatically reach the commercial and Medicaid patients who make up most pediatric care. Plan around the timed codes, not around GSLPP.
What CMS actually proposed
Some clinicians and organizations told CMS that the ten new timed codes replacing 92507 may not fully reflect the time and intensity of treating pediatric patients. Pediatric sessions are shorter on average, carry more regulation and transition overhead, and often move across more than one area of need. Under a strictly timed structure, a lot of legitimate pediatric work risks falling below billable thresholds. We walk through that math in our 8-minute rule breakdown.
In response, CMS proposed GSLPP with these features:
- It is a single, untimed code, reported once per patient per day, regardless of session length or which areas you treated.
- It was valued using 92507 as the primary crosswalk, carrying a work RVU of 1.30 based on roughly 60 minutes of personally performed treatment.
- It would be designated an always therapy service and would be subject to multiple procedure payment reduction.
- It was created through Medicare rulemaking, not the AMA CPT process that produced the ten new codes.
- It is a HCPCS Level II code built for Medicare programmatic purposes.
On paper, GSLPP would preserve something close to the old 92507 experience: one code, one payment per day, no stopwatch. The catch is where it applies.
Timed CPT codes vs. the proposed pediatric G-code
| The ten new CPT codes | Proposed pediatric G-code (GSLPP) |
|---|---|
| Built through the AMA CPT and RUC process | Proposed separately by CMS through Medicare rulemaking |
| Published in the CPT 2027 code set on September 9, 2026 | Still a proposal, pending the November 2026 final rule |
| Used by essentially every payer that accepts CPT | Medicare Part B only, unless a payer chooses to adopt it |
| Five treatment categories, timed reporting (30-minute base plus 15-minute add-ons) | One broad, untimed pediatric code |
| Payment varies by treatment area and time | One payment regardless of treatment or time |
Why GSLPP probably will not change your 2027
GSLPP is worth understanding, but four things keep it from being the reprieve it looks like.
1. It is Medicare Part B, and pediatrics barely lives there
Medicare Part B primarily covers outpatient care for adults. Very few pediatric patients are billed under Medicare Part B, so even if GSLPP is finalized, most pediatric caseloads would not report it at all.
2. Other payers are not required to follow
Medicaid, Medicare Advantage, and commercial plans set their own coding and payment rules. Medicare sometimes sets a baseline others look to, but no commercial or Medicaid plan is obligated to recognize GSLPP. For a pediatric practice, whose revenue comes from exactly those payers, that is the whole question, and it is unanswered.
3. It is a proposal, not a final rule
The public comment period closed September 14, 2026, and the final rule is expected in November 2026. GSLPP could still change substantially or disappear. ASHA has said it did not request the code and formally urged CMS to reject it, so the outcome is genuinely open.
4. It carries its own tradeoffs
A broad untimed code can recreate the exact problem that got 92507 reviewed in the first place: when everything rolls up into one code, claims data cannot show whether rising use reflects more need, longer sessions, or something else. CMS even defined pediatric in more than one way across the proposed rule, referencing both age 18 and age 21 in different sections, which signals how unsettled this is.
So what does it mean for a pediatric SLP?
The honest read: GSLPP is a signal, not a plan. It tells you CMS heard the pediatric concern, which is worth something. But your billing runs on commercial and Medicaid contracts, and those payers are moving toward the ten timed codes when 92507 is deleted on January 1, 2027. A Medicare-only proposal does not change what you need to have ready.
Three things to do now:
- Keep preparing for timed codes. Document time per treatment area, audit your session lengths, and get your systems ready. Nothing about GSLPP changes that.
- Watch your actual payers. If Medicare Part B is a real part of your caseload, follow GSLPP closely. If it is not, track what your top commercial plans and your state Medicaid program say about 2027 instead.
- Put the final rule on your calendar. Comments closed on September 14, 2026, so the next real information arrives with the November 2026 final rule. That is when you will know whether GSLPP survives and what the Medicare values actually are.
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Frequently asked questions
Is GSLPP replacing the new SLP CPT codes?
No. GSLPP is a separate Medicare proposal that would sit alongside the ten new CPT codes as an option for pediatric services under Medicare Part B. The CPT codes are still the core change for nearly every payer, and they were published in the CPT 2027 code set on September 9, 2026.
Will commercial insurance or Medicaid pay GSLPP?
Unknown, and you should not count on it. Each payer sets its own rules, and as of the September 2026 close of the comment period there is no guarantee any non-Medicare payer will recognize it.
Is GSLPP final?
No. It remains a proposal. The comment period closed September 14, 2026 and CMS is expected to issue the final rule in November 2026, which is when GSLPP is either finalized, changed, or dropped.
If I mostly bill commercial or Medicaid, does GSLPP help me?
Probably not. GSLPP is a Medicare Part B code. Unless your commercial and Medicaid payers choose to adopt something like it, your 2027 planning should center on the ten timed codes.
Do I still need to prepare for timed codes?
Yes. The ten timed codes are the change most payers are expected to follow when 92507 is deleted January 1, 2027. Prepare for those regardless of what happens with GSLPP. Our full guide to the 92507 change and the free planner above walk you through it.
Coral Care handles billing, credentialing, and compliance for pediatric OTs, SLPs, and PTs delivering care in person across nine states. Grab the free 2027 billing planner above, and when the new rules land, we update our systems so you can keep treating kids.
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