On Friday, May 23rd, the Centers for Medicare and Medicaid Services (CMS) posted MLN 13922, which discussed technical updates to Chapter 15 of the Medicare Benefit Policy Manual. Specifically, they discussed Section 230.3, which outlines the qualifications for Speech Language Pathologists (SLP) furnishing outpatient SLP services. CMS states in the MLN that the associated Change Request (CR) contains no new policy. AHCA encourages providers to maintain existing personnel and billing practices related to SLP service provision.
The SLP requirements have been effective since January 1, 2015, and are contained in statute (section 1861(II)(4)(A) of the Social Security Act). In the MLN, CMS was simply updating the manual to reflect this decade-long policy.
These provisions define a qualified SLP as an individual with a master’s or doctoral degree in SLP and meet either of these requirements:
- Is licensed as an SLP by the state in which they provide services; OR
- In the case of a person who practices in a state that doesn’t license SLPs, they must have:
- Successfully completed 350 clock hours of supervised clinical practicum (or be in the process of accumulating supervised clinical experience);
- Performed at least 9 months of supervised full-time SLP services after obtaining a master’s or doctoral degree in SLP or a related field; and
- Successfully completed a national examination in SLP approved by the HHS Secretary.
AHCA will continue to advocate for additional clarity from CMS regarding SLP qualifications and the impact of any changes being considered, as well as provide any updates as they become available. Please contact AHCA’s John Kane and Dan Ciolek if you have any questions.