ASHA Requirements and Payer Policies for SLP Clinical Fellows and Mentors

To ensure that Clinical Fellow(s) meet the requirements established by federal and state laws and regulations, ASHA policy, and payer requirements, the following key considerations are recommended for Clinical Fellows and their mentors to review together. It is important to note that in order to determine whether a Clinical Fellow is authorized to practice and have their services reimbursed, the Clinical Fellow and their mentor must be aware of the intersection of payment policy, state and federal laws and regulations, and ASHA’s Code of Ethics (2016). These requirements do not exist in a vacuum; rather, they interact to drive appropriate practice and reimbursement.

For more details on supervision and reimbursement considerations see our page on Supervison of Clinical Fellows and Audiology Externs: Billing and Payment Compliance.

ASHA’s Clinical Fellowship Requirements

The following information about the ASHA Clinical Fellowship (CF) experience, including requirements and forms, is available on the ASHA website:

These ethics-related resources may also be helpful:

Payer Personnel Qualifications

Payers can have different requirements for provider qualifications, so the following questions should be considered for each payer:

Does the payer require the ASHA Certificate of Clinical Competence (CCC)?
Does the payer require licensure? A few states do not currently license Clinical Fellows and so payers may require a higher level of supervision by a licensed speech-language pathologist (SLP) in order for the unlicensed Clinical Fellow to be eligible to treat patients and be reimbursed.

Medicare

The Social Security Act, which governs the Medicare program, requires licensure (if the state licenses SLPs) and does not explicitly require the SLP to have the ASHA CCCs in order to be reimbursed. As noted below, all states currently license SLPs but not all states license Clinical Fellows. Additional information on Medicare supervision requirements is available on ASHA’s website.

Private Payers

Requirements such as the CCC and licensure vary widely among private payers, so it is best to check with each payer with which you contract to determine the personnel qualifications.

State Medicaid Agencies

Each state Medicaid agency also varies in terms of its personnel qualifications, so verification of these requirements with your state’s Medicaid agency is critically important. More information regarding Medicaid requirements is available in ASHA's Medicaid Toolkit.

State Law Requirements

As of 2017, all states and the District of Columbia require licensure for SLPs. The vast majority of states currently require and provide provisional licensure for Clinical Fellows. In states that do not license Clinical Fellows, they may be authorized to practice, but their services might not be reimbursable when the payer, such as Medicare, requires licensure. Clinical Fellows can check ASHA's state licensure information or contact their state licensure board.

Billing for the Services of an Unlicensed Clinical Fellow

As noted above, the ability to bill for the services of an unlicensed Clinical Fellow depends on the payer’s requirements. If the payer requires licensure for reimbursement, then you should ask the payer under what circumstances, if any, the unlicensed Clinical Fellow’s services may be reimbursable. For example, Medicare treats unlicensed Clinical Fellows as students, meaning that a licensed SLP must provide a defined level of supervision (separate from ASHA’s Clinical Fellowship mentorship standards). This supervision is related to both the physical delivery of services and participation in documentation. More details on Medicare supervision requirements for students (including Clinical Fellows in states without Clinical Fellow licensure) is available on the ASHA website.

Private payers and state Medicaid agencies also have flexibility in establishing personnel qualifications and supervision requirements for students, speech-language pathology assistants, and other unlicensed staff. These requirements are not standardized, so it is important to check with each payer directly to determine their requirements. One other “wrinkle” is that payers often provide lower reimbursement rates for services provided by Clinical Fellows, so it is important to verify these standards as well.

Questions?

ASHA’s requirements for the completion of the Clinical Fellowship: certification@asha.org.
Reimbursement and payer policy: reimbursement@asha.org.
State licensure laws and regulations: states@asha.org
ASHA’s ethical standards: ethics@asha.org.