Advocacy Updates
CIS-EI Medicaid Billing Changes
(May 29th, 2026)
VSHA continues to collaborate on behalf of SLP, OT, and SLP professionals through our trialliance connections.
Please see the letter below submitted during the Public Comment Period in Response to Proprosed Changes to CIS-EI Medicaid Payments:
To Whom It May Concern, Medicaid Policy Unit:
On behalf of the leadership of the Vermont Speech-Language-Hearing Association (VSHA), we are writing to provide comment on Proposed GCR 26-048, CIS-EI PT, OT, and SLP Evaluations.
VSHA represents speech-language pathologists, audiologists, speech-language pathology assistants, students, and related professionals across Vermont, including multiple members who have worked within Vermont’s Children’s Integrated Services Early Intervention (CIS-EI) system for many years. Our association is committed to supporting equitable access to high-quality, evidence-based services for children and families across the state.
Although the proposed rule change presents the new evaluation rate as an increase over standard PT, OT, and SLP code rates, it does not acknowledge that this change represents a significant decrease from what CIS-EI providers have actually been paid for more than 20 years. Until April 15, 2026, providers received $350 for these evaluations. Under the proposed rule, payment would be reduced to $200 for the same service.
The scope of these evaluations has not changed, nor have the time requirements, documentation standards, clinical complexity, or coordination responsibilities with CIS teams and families. These evaluations often require specialized clinical knowledge, family-centered assessment, interdisciplinary collaboration, care coordination, and documentation that extends beyond the face-to-face evaluation itself.
The rule estimates annual savings of $73,482 in Medicaid funds and $37,474 in IDEA Part C funds. In practical terms, this represents more than $110,000 removed from reimbursement for highly trained, specialized providers who are already operating within narrow financial margins.
Many small private practices, individual providers, and CIS fiscal agents have built their budgets and service delivery models around the rates that were previously in place. Provider reimbursement has already declined steadily over the past decade when accounting for inflation, administrative burden, workforce shortages, and increasing service demands. This additional reduction creates a financially unsustainable model that will further limit the availability of PT, OT, and SLP evaluation services for children from birth to age three.
Early Intervention services are evidence-based and essential. Timely access to PT, OT, and SLP evaluations supports improved developmental outcomes, reduces strain on families, informs appropriate service planning, and may help prevent more intensive and costly special education and support needs later in childhood.
This proposed rule change risks worsening an already serious access problem for Vermont children and families seeking high-quality Early Intervention PT, OT, and SLP services. At a time of growing workforce shortages, increasing referral volume, and persistent challenges in recruiting and retaining specialized providers, reducing reimbursement for these evaluations will make it even harder to maintain an adequate provider network and meet the needs of vulnerable children and families.
We respectfully urge the Department to reconsider this proposed change and adopt a rate structure that reflects the true cost, clinical complexity, and long-term value of these essential Early Intervention services.
Sincerely,
Sierra Downs, MA, CCC-SLP
2025-2026 President, Vermont Speech-Language-Hearing Association
On behalf of VSHA Leadership
(March 17th, 2026)
Dear members and colleagues,
Following the March 13th release of the EI Medicaid Billing Impact Survey, VSHA continues to collaborate with APTA Vermont and VOTA to coordinate next steps.
As a reminder, effective April 15, 2026, CPT code T1023 will no longer be reimbursed for CIS-EI, requiring use of lower-paying discipline-specific evaluation codes.
Next steps:
- Finalize and analyze survey data
- Develop a joint advocacy brief
- Prepare for further engagement with Vermont Medicaid leadership
A follow-up cross-disciplinary meeting is scheduled for March 20th, 2026. Additional updates will be shared soon.
VT Medicaid EI Provider (PT/OT/SLP) Payment Survey
(March 13th, 2026)
Dear valued members, colleagues, and related stakeholders:
As many of you will be aware, the Vermont Medicaid Division has announced that CPT code T1023 will be discontinued for use in Children’s Integrated Services–Early Intervention (CIS-EI) for Physical Therapy, Occupational Therapy, and Speech-Language Pathology evaluations effective April 15, 2026. Claims submitted for dates of service on or after April 16, 2026 may be subject to recoupment. The T1023 code currently reimburses $350 for initial assessment activities. Going forward, providers will be required to bill discipline-specific evaluation codes for PT, OT, and SLP services, which reimburse approximately $83.02 for PT evaluations, $85 for OT evaluations, and an estimated $191 for SLP evaluations. Importantly, there is no change to EI assessment requirements or documentation standards; the change is limited to coding and results in substantially lower payment for the same services.
This change comes at a time when payment rates for PT, OT, and SLP services are already declining, while the cost of delivering complex Early Intervention services - particularly in a rural state like Vermont - continues to rise. The anticipated reduction in reimbursement threatens the sustainability of EI services that are critical to supporting young children and families and that generate long-term cost savings across education, health, and social service systems. Maintaining a strong EI system is essential to achieving positive outcomes for children and responsible stewardship of public resources.
In response, leadership from APTA VT, VOTA, and VSHA have come together to coordinate next steps and address concerns raised by members and stakeholders. A survey has been developed to collect data from EI specialty providers impacted by this change. The information gathered will help identify trends, quantify impacts, and inform discussions with key stakeholders, with the goal of finding solutions that support providers while ensuring continuity of high-quality services for the children and families served by Early Intervention.
Survey Link: https://forms.gle/XHtc83SUQwJRAywf9
We strongly encourage affected providers to complete the survey so their experiences and perspectives are represented. Through collective input and a coordinated approach, we aim to develop a clear, consistent message and pursue effective advocacy.
Thank you for your participation and continued commitment as we work together on this important issue.
- VSHA Leadership
(March 11th, 2026)
- VSHA signed the (link) APRN Professional Designation support letter + ongoing ASHA advocacy for SLP & AUD professional designation at federal level.
- VSHA also endorsed H.618 Memo in support of Vermont School Counselors Association (VTSCA) ensuring that at least 80% of a school counselor’s time is protected for direct work with students.
VSHA Advocacy Update from the State Capitol
(January 30, 2026)
Meeting with VT-NEA
VSHA leadership met with Vermont-NEA (VT-NEA), the statewide teachers’ union representing educators and many school-based professionals across Vermont.
Representing VSHA were:
Sierra Downs, MA, CCC-SLP, President
Miya Wilson, MA, CCC-SLP, Treasurer and Legislative Chair
Nicole Lord, BA, SLPA, SLPA Liaison
Our discussion focused on three core pillars guiding VSHA’s legislative advocacy:
1. One License Pathway
We advocated for streamlining professional oversight by consolidating licensure under the Office of Professional Regulation (OPR), rather than maintaining dual oversight between OPR and the Agency of Education (AOE). A single licensure pathway strengthens professional standards, reduces redundancy, and aligns speech-language pathology with other regulated professions in Vermont.
2. SLPA Licensure, Regulation, and Recognition
We emphasized the urgent need to establish formal licensure and regulatory standards for Speech-Language Pathology Assistants (SLPAs). Vermont currently lacks structured regulatory oversight of SLPAs, resulting in inconsistencies in training, supervision, and accountability. Formal licensure through OPR would provide professional recognition, protect students, and support supervising SLPs.
3. Salary Advocacy for School-Based SLPs
We addressed compensation inequities affecting school-based SLPs. School SLPs are often on the teacher salary scale. Recruitment and retention challenges persist statewide, particularly in rural districts. Competitive and equitable salary structures are essential to sustaining the workforce and ensuring continued access to services for Vermont students.
Watch: VSHA's Testimony Before HGO
VSHA leadership also appeared in person before the Vermont House Government Operations Committee (HGO) at the State Capitol.
Sierra Downs, Miya Wilson, and Nicole Lord were present at the front of the committee room to provide testimony and answer questions regarding SLPA regulation and licensure reform.
HGO oversees professional regulation and licensure matters in Vermont. During testimony, VSHA emphasized the importance of formally including SLPA licensure in the upcoming OPR bill and requested that the proposal undergo a Sunrise Review through OPR. The last Sunrise Review related to speech-language pathology occurred in 2014. Given the evolution of workforce needs, supervision standards, and service delivery models, an updated review is warranted.
We reinforced that SLPA regulation is both a workforce solution and a quality assurance measure. Establishing licensure standards protects students, clarifies supervision expectations, and aligns Vermont with national regulatory models.
VSHA will continue to advocate for these priorities and will provide updates as the OPR bill progresses.