Most university SLP clinic directors assume Medicare is off the table for them. Either the student supervision model disqualifies them, they think, or Medicare is just too complicated to bother with. Neither assumption is accurate. And more importantly — if your clinic is already treating Medicare beneficiaries, enrollment may not be optional.
Medicare Part B covers outpatient speech-language pathology and audiology services, and university training clinics are not excluded from that coverage.1 Federal law requires any clinician who provides covered services to a Medicare beneficiary to enroll in Medicare and submit claims. Accepting cash instead isn't a compliant workaround — it's a violation.
This post walks through what that means in practice: the mandatory enrollment rules, how the student supervision model works under Medicare Part B, the CPT codes that generate real revenue, what changed for telehealth as of October 2025, and where to start if your clinic is ready to enroll.
Medicare Part B Covers University SLP Clinics — And Enrollment May Not Be Optional
Let's start with the piece most directors get wrong. Medicare Part B covers outpatient speech-language pathology services, and the definition of "outpatient" includes university training clinics. Your clinic's affiliation with a university doesn't disqualify it from Medicare reimbursement.
What makes this more than just a billing opportunity is the mandatory enrollment rule. Under federal regulations, any audiologist or speech-language pathologist who furnishes covered services to Medicare beneficiaries must enroll as a Medicare provider and submit claims for those services.2 There is no opt-out provision. And critically, enrolled or not, you cannot legally accept cash from a Medicare beneficiary for a covered service — the prohibition runs in both directions.
Most university programs don't know this. They assume that because they're primarily a training environment, or because they use a sliding scale, Medicare doesn't apply. But if a patient in your clinic is 65 or older (or otherwise Medicare-eligible) and you're delivering covered speech-language pathology or audiology services, the obligation to enroll and bill is already there.
Other universities have navigated this successfully. Programs at Florida Atlantic University, the University of Alabama Speech and Hearing Center, and Illinois State University have all enrolled in Medicare Part B and integrated billing into their clinic operations. It adds an administrative layer — but it's one that generates meaningful revenue while keeping the clinic compliant.
The good news is that the structure most university SLP programs already have in place (qualified supervisors directing care, detailed session documentation) maps closely to what Medicare actually requires.
The Supervision Rule: How Student Clinicians Fit Under Medicare Part B
If there's one thing to get right about billing Medicare at a university SLP clinic, it's the supervision rule. And it's not as complicated as it sounds once you understand what Medicare is actually asking for.
Medicare Part B allows billing in a student-supervised setting under a specific condition: a qualified, ASHA-certified clinician must be physically present in the treatment room for the duration of the session, actively directing the care, making skilled clinical judgments, and signing all documentation as the clinician of record.3 The student can be the one delivering the treatment under the supervisor's direction. But the supervisor must be there — in the room, not down the hall.
So what does "present in the room" actually mean in practice? It means the supervising SLP or audiologist cannot step out to treat another patient or supervise a different student while a Medicare session is running. One Medicare session, one supervisor, full presence. That's the rule.
This is also where a common misconception trips people up. In some physician-led outpatient settings, Medicare allows "incident-to" billing, which permits more flexible supervision arrangements. But incident-to billing does not apply in outpatient therapy settings — including university SLP clinics.3 Your clinic falls under the stricter in-room presence requirement.
From a documentation standpoint, this means every session record for a Medicare patient needs to clearly reflect the supervisor's clinical involvement. The student may draft the SOAP note, but the supervisor reviews it, makes any necessary edits, and signs it. In Medicare's framework, the supervisor is the treating clinician. The student isn't billing as an independent provider — they're learning under the direction of the clinician of record.
For most university SLP programs, this level of supervisor involvement is already standard practice. The documentation habits and oversight workflows you've built for training purposes are exactly what Medicare billing requires. The documentation just needs to be explicit about it.
Getting Enrolled: NPI Numbers and Medicare Provider Applications
Once you've confirmed that your clinic serves (or will serve) Medicare beneficiaries, enrollment is the next step. There are two separate applications typically required, and it helps to understand what each one covers.
First, each supervising clinician who will bill Medicare needs an individual NPI — a Type 1 National Provider Identifier — and must enroll as an individual Medicare provider using CMS Form 855I.4 If your supervisors already have NPIs from previous clinical work, confirm those are active and up to date.
Second, the clinic entity itself typically needs to enroll as a group/organization provider using CMS Form 855B and a Type 2 (organizational) NPI. The clinic entity enrollment establishes the billing entity. Individual supervisors then bill under that group.
Both applications go through PECOS — the Provider Enrollment, Chain, and Ownership System — which is CMS's online enrollment portal. Paper applications are accepted, but they take longer. Build in 60–90 days from application submission to active Medicare enrollment, sometimes longer.4 If you're hoping to start billing by a specific semester or fiscal year, plan enrollment well in advance.
One other administrative detail worth knowing: Medicare enrollment isn't permanent. Providers must revalidate their enrollment with CMS every five years. Setting a calendar reminder when you complete initial enrollment will save you from an inadvertent lapse.
Your specific enrollment applications are processed by a Medicare Administrative Contractor (MAC), which is a regional CMS contractor assigned to your state. Your MAC handles enrollment, claims processing, and provider inquiries. Knowing which MAC covers your state is useful when you have questions about processing status or claims issues down the line.
CPT Codes and What Medicare Actually Pays for SLP and Audiology Services
Once your clinic is enrolled, here's what Medicare Part B covers in terms of speech-language pathology services and what the payment rates look like.
The core evaluation codes are 92521 (fluency evaluation), 92522 (speech sound production evaluation), 92523 (language comprehension and expression evaluation), and 92524 (behavioral and quality of voice analysis).5 For treatment, 92507 covers individual treatment for speech, language, voice, communication, or auditory processing disorders — and it's the code you'll use most often for ongoing therapy sessions.
Audiology diagnostic services are billed using codes in the 92550–92588 series, covering everything from pure tone audiometry to tympanometry and auditory evoked potentials.
Medicare pays based on the Physician Fee Schedule (MPFS), which CMS updates annually. At 2025 MPFS rates, evaluation codes for SLP services typically yield $80–$150 per session depending on the specific code and your clinic's geographic payment locality — urban areas often reimburse higher than rural.5 Medicare's payment structure covers 80% of the approved amount; the patient (or a supplemental Medigap plan) covers the remaining 20%.
Even a modest volume of Medicare patients adds up. A clinic with 10 Medicare patients seeing an average of 1–2 sessions per week is generating meaningful revenue that wasn't there before. For programs that previously turned Medicare-eligible patients away or directed them elsewhere, enrollment can make your services accessible to an underserved patient population while building your clinical training volume.
Medicare does impose a financial limitation on outpatient therapy services called the KX modifier threshold, which changes annually and requires additional documentation to exceed. Worth familiarizing your billing staff with this before you hit it.
What Changed in October 2025: Medicare Telehealth for SLP and Audiology Services
If your clinic offered telehealth services to Medicare patients during or after COVID, this update matters. Medicare's expanded telehealth flexibilities for audiologists and speech-language pathologists expired on September 30, 2025.6 As of October 1, 2025, Medicare Part B does not cover telehealth services delivered by audiologists or SLPs.
That means any Medicare patient telehealth sessions conducted after September 30, 2025 are not reimbursable under Medicare Part B. Claims submitted for those services will be denied.
For clinics that shifted to hybrid or fully telehealth models during the pandemic — or that have continued offering telehealth as a scheduling convenience — this is a real operational constraint. Medicare patients need to be scheduled for in-person sessions. Full stop.
This doesn't affect all of your payers. Medicaid and many commercial insurance plans still cover telehealth for SLP and audiology services. But for Medicare specifically, service delivery needs to happen in-person to be billable.
The practical implication for scheduling: verify insurance type before assigning a session modality. If a patient is Medicare-primary, their appointments need to be in-person sessions. Getting this into your scheduling workflow now will prevent claim denials and patient confusion later.
Where to Start: A Practical Checklist for University Clinics
Enrollment sounds like a lot, but the process is more straightforward once you break it into discrete steps. Here's a practical sequence:
1. Audit your current patient population. Identify patients who are 65+ or otherwise Medicare-eligible. These are the patients who trigger the mandatory enrollment obligation.
2. Designate your Medicare-enrolled supervisors. These are the clinicians who will bill as treating providers. Confirm they hold ASHA certification and current CCC credentials.
3. Obtain NPIs if needed. Each supervisor needs a Type 1 NPI; the clinic entity needs a Type 2 NPI. Both are obtained through NPPES, the National Plan and Provider Enumeration System, at nppes.cms.hhs.gov. NPI registration is free and relatively quick.
4. Enroll through PECOS. Submit CMS-855I for each supervising clinician and CMS-855B for the clinic entity. Track your MAC's processing timelines — plan for 60–90 days or more.
5. Set up your claim submission workflow. Medicare claims submit electronically to your state's MAC. A clearinghouse integration handles this, and most modern EMR systems connect to a clearinghouse directly.
6. Document supervision explicitly in every Medicare session record. The audit trail is what protects you. Every session note should reflect the supervisor's presence, clinical judgment, and sign-off. If a Medicare claim is ever reviewed, your documentation is your defense.
Clinics that have gone through this process consistently report that the enrollment paperwork is the most labor-intensive part. Once you're enrolled and your billing workflow is running, it becomes routine.
Ready to Build a Billing Workflow Around Your Supervision Model?
ClinicNote's billing module was built for supervised clinical training environments. Supervisors are linked to every session, documentation approval workflows are built in, and electronic claim submission connects directly to your clearinghouse. If you're a university SLP or audiology clinic thinking through Medicare enrollment, see how ClinicNote handles the billing and documentation side of the process. Schedule a demo.
Sources
- https://www.asha.org/practice/reimbursement/medicare/medicare_medicaid/
- https://www.asha.org/practice/reimbursement/medicare/mandatory_enrollment/
- https://www.ucdenver.edu/docs/librariesprovider204/shc-documents/medicare-part-b-student-billing.pdf
- https://pecos.cms.hhs.gov/pecos/login.do
- https://www.cms.gov/medicare/physician-fee-schedule/search
- https://www.cms.gov/medicare/coverage/telehealth