Members need to be aware that the Part C rules removed the requirement that states must employ only personnel who meet the highest requirement for the professions in the state. Part C rules require personnel to meet any state-approved certification, licensing or regulations for the profession or discipline in the area in which personnel are providing early intervention services.
ASHA standards, which are reflected in most licensing requirements, guarantee that only the most competent individuals will be allowed to engage in professional practice. ASHA members and the children and families served under Part C need to be aware that allowing states to identify competency standards may result in a two-tiered system in which children and families receiving Part C educational services may be served by individuals not as qualified those receiving medically based early intervention services.
Members should recognize that private and public insurers, such as Medicaid, recognize only the highest personnel standards and will not reimburse for services provided by individuals who do not meet those standards (i.e., Certificate of Clinical Competence [CCCs] or its equivalent). This includes any state-approved requirements that do not meet the definition of highly qualified as defined in the Medicaid regulations and the ASHA standards.
ASHA members should work with the state-identified lead agency, Part C administrators, and hiring officials to underscore the importance of hiring qualified personnel and helping reduce personnel shortages. ASHA documents on the use and value of employing highly qualified professionals can be found on the ASHA website.
Confusing and competing standards may create difficulties not only for ASHA members and other professional providers, but also for the children and families being served under Part C. Members may wish to provide consumers with information and resources to assist them in advocating for highly qualified personnel.
Given the U.S. Department of Education's recognition of personnel shortages, members should take the opportunity to contact their state speech-language-hearing association, academic programs, and other professional organizations whose members provide early intervention services as well as their state Part C program to develop strategies to ensure that an adequate supply of qualified personnel is available to meet the needs of children and families with disabilities eligible for Part C services. ASHA resources to assist with personnel shortages can be found on ASHA's website.
Because insurers (e.g., Medicaid) only reimburse for services provided by highly qualified personnel, ASHA members need to ensure that employers are aware that individuals with lesser qualifications, such as those hired under emergency provisions, will not be reimbursed for their services.