New Medicare Time Requirement to Bill for Caregiver Training Services
March 17, 2025
The Centers for Medicare & Medicaid Services (CMS) has introduced a new billing time requirement for Caregiver Training Services (CTS) for speech-language pathologists (SLPs). Effective January 1, 2025, time-based Current Procedural Terminology (CPT) codes for caregiver training for functional performance (97550 and 97551) and caregiver training for primary care services (G0451 and G0452) need to be provided face-to-face with the caregiver without the patient present for the full time listed in the code descriptors.
This means the initial 30 minutes of 97550 and G0541 can only be billed if the full 30 minutes is provided and each additional 15 minutes of 97551 and G0542 can only be billed if the full 15 minutes is provided for each 15-minute unit. The CPT codes related to group caregiver training―97552 and G0543―are not timed, so this "full-time" concept does not apply to them.
SLPs should note that this means the 51% rule does not apply to CTS codes billed to Medicare. The 51% rule for timed codes states that a timed code can be billed when face-to-face time spent in evaluation or treatment attains or exceeds 51% of the time designated in the code's descriptor.
This new guideline on the full-time requirement for CTS codes currently applies only to Medicare. Medicare has not placed the full-time requirement for other timed codes. This does not apply to Medicaid or private payers. SLPs should check directly with individual payers on their policies and guidelines.
ASHA is seeking further clarification on this new requirement from CMS and will share any relevant updates with SLPs.
Resources
For more information, see ASHA’s resources on caregiver training codes and the right time to bill a code. You can also refer to CMS’ CTS FAQs to learn more about this new guideline.
Questions?
Contact ASHA's health care policy team at reimbursement@asha.org.
