2013 Public Policy Agenda
The following issue is managed at the federal level.
Medicare Reimbursement and Coverage Policies
ASHA members who treat Medicare beneficiaries constantly face the challenges of working with the Medicare system. Speech-language pathologists (SLPs) continue to deal with the results of Congress's inability to find a solution regarding the Medicare therapy reimbursement cap on speech and physical therapy services; audiologists must contend with the lack of comprehensive coverage of services, specifically including rehabilitative services. Both SLPs and audiologists seek fair compensation for their services. In response to these challenges, ASHA will
- advocate for equitable reimbursement for audiologists and SLPs and coverage for beneficiaries of Medicare health plans;
- promote an alternative payment policy for Medicare outpatient therapy services to eliminate the reimbursement cap placed on speech-language pathology and physical therapy services;
- support reform of the sustainable growth rate formula to provide a more permanent solution in determining reimbursement under the Medicare Part B fee schedule;
- support Medicare coverage of audiologic diagnostic and rehabilitative services and the right of audiologists to opt out of the Medicare program;
- represent both SLPs and audiologists before the Centers for Medicare and Medicaid Services to ensure the maintenance and/or expansion of appropriate values, coverage, and reimbursement rates.
Federal and State Level
The following issues are managed at both the federal and state level.
Federal and State Funding for Services of School-Based Members
Congress and states continue to seek budget cuts and create additional hurdles for funding; staff cutbacks, increased paperwork, and the increased implementation of accountability measures create uncertainties for school-based members and threaten to undermine their ability to provide effective services to children. To support our members in school settings, ASHA will
- advocate for reauthorization of the Elementary and Secondary Education Act (ESEA) and Individuals with Disabilities Education Act (IDEA) and promote the inclusion and funding of speech, language, and hearing services and devices in all federal literacy legislation;
- support consistent language and common terminology, including the use of the term highest qualified provider in ESEA and IDEA;
- promote adoption of appropriate accountability/evaluation measures for specialized instructional support personnel (SISPs) in education settings through collaboration with members, stakeholders, and decision makers at the state and local level;
- oppose cuts in education funding;
- seek alternatives to help reduce the paperwork and administrative burden on school-based SLPs and audiologists so they can spend more time with students;
- advocate for states to adopt IDEA Part C Infants & Families Program requirements;
- advocate for waivers in IDEA Part C maintenance of effort to help keep states in the program while granting them temporary funding flexibility;
- promote the reallocation of IDEA Part D funds so that they are in line with ASHA's school-based and graduate academic needs.
Hearing Health Care
The United States has seen an overall increase in the number of individuals with reported hearing loss. For example, the prevalence of hearing loss among a sample of U.S. adolescents age 12 to 19 years was greater in 2005-2006 compared with 1988–1994 (The Journal of the American Medical Association, Aug. 18, 2010). Consequently, there is greater need-and demand-for affordable and appropriate hearing devices and for educational efforts to increase public awareness of hearing conservation issues. In following our vision to make effective communication, a human right, accessible and achievable for all, ASHA will advocate for consumer access to safe and effective hearing health care services, devices, hearing aids, and environments by
- supporting hearing aid tax credit legislation to increase affordability of hearing aids;
- supporting (a) Food and Drug Administration (FDA) regulations related to Internet and retail sales of hearing aids and personal sound amplification products (PSAPs) and (b) Federal Trade Commission (FTC) oversight of deceptive advertising by sellers of PSAPs;
- supporting reasonable, cost-effective regulations and standards set by the American National Standards Institute (ANSI) and the Occupational Safety and Health Administration (OSHA) to prevent noise-induced hearing loss in the environment;
- promoting a comprehensive system of children's hearing health care services, including
- implementation of the Early Hearing Detection and Intervention (EHDI) program, with specific focus on comprehensive follow-up, appropriate intensity of intervention, and coordinated management across state and federal agencies;
- adoption of state hearing screening standards for school-age children;
- provision of insurance coverage of hearing aids, cochlear implants, and related devices and services for children.
Loan Forgiveness as a Recruitment and Retention Tool
The Pew Research Center reported that, in 2010, nearly one in five U.S. households-22.4 million-had college debt, a proportion that has almost doubled in just over 20 years. ASHA supports strategies to increase recruitment and retention of SLPs and audiologists through financial aid and loan forgiveness. We will continue to monitor federal incentives pertaining to Pell and Stafford loans and support state legislative efforts to adopt loan forgiveness provisions for SLPs and audiologists.
Medicaid Reimbursement and Coverage Policies
Due to the changes in health care mandated by the Patient Protection and Affordable Care Act (ACA), more individuals will potentially be eligible for Medicaid services. At the same time, states continue to seek ways to reduce the financial burden of Medicaid. Therefore, ASHA members will face the potential of increased caseloads of Medicaid-eligible clients, reduced reimbursement rates, and increased administrative burden, along with the challenge of balancing the need for increasing the number of clients on the caseload to compensate for lower reimbursement rates. To help ASHA members, we will
- advocate for coverage of services provided by SLPs and audiologists, including maintaining funding for services mandated by the federal Early Periodic Screening, Diagnosis, and Treatment (EPSDT) program, ensuring that services are based on the needs of the clients served, and establishing reasonable beneficiary eligibility requirements;
- promote reimbursement for devices, including but not limited to hearing aids, cochlear implants and related equipment, and augmentative and alternative communication (AAC) devices.
Patient Protection and Affordable Care Act
With passage of the ACA, states are faced with the challenges of implementing the law's requirements. ASHA will offer support for state adoption of the ACA requirements, including insurance coverage of Essential Health Care Benefits as implemented through federal regulations. In addition, we will provide information and support for member involvement in state efforts to implement the Essential Health Benefits package to ensure that appropriate habilitative and rehabilitative services will be covered by health insurers.
Private Health Plans Reimbursement and Coverage Policies
Private health plans vary significantly in their coverage policies, reimbursement rates, and interpretation of federal and state regulations. ASHA will continue to
- advocate for coverage of services provided by SLPs and audiologists and provide input to coverage policies in private insurance
- assist members with insurance appeals for medically necessary services.
As technology advances, the shift in the way we deliver services offers new opportunities to reach clients in ways we never have before. In addition, many rural areas either lack access to or face a shortage of SLPs and audiologists to deliver services. ASHA will help its members and consumers by advocating for the recognition and coverage of services delivered through telepractice and monitor opportunities to advocate for funding through federal and state legislation and regulation.
The following issues are managed at the state level.
Comprehensive (Universal) Licensure
Through national certification (i.e., ASHA’s CCC credential), SLPs and audiologists are uniquely qualified to assess and treat individuals with communication disorders, regardless of geographical location or practice setting. However, state regulatory agencies create unnecessary barriers by requiring members to seek and maintain different licenses and/or certifications depending on practice setting. Many states have recognized the advantage of issuing a single license for SLPs/audiologists to practice. ASHA will continue to advocate for a comprehensive (universal) license in all states, which would allow members to practice in any setting and improve licensure portability across states.
With the shortage of SLPs and audiologists, more and more states seek options for identifying different levels of standards for service providers. ASHA supports the adoption of model licensing language and implementation of a service continuum that defines the credentials and competency requirements for SLPs, audiologists, speech-language pathology assistants (SLPAs), and audiology assistants to ensure that
- regulations in the state include, education, training, and supervision requirements to promote uniform standards for the full continuum of speech-language pathology and audiology service providers across the country;
- quality services are delivered to individuals with communication disorders.
State departments of education (DOE) hire individuals to implement DOE policies, assist with educator questions, and provide training and support to the field. SLPs and audiologists are hired by the state as consultants to assist members in the state and provide a unique understanding of the professions as well as DOE requirements. With increased demands on state budgets, fewer speech-language pathology and audiology consultants are being hired and/or retained. ASHA, in collaboration with state associations and organizations, shall support members, and states seeking to hire members as consultants to the DOE and shall promote the hiring and retention of SLPs and audiologists serving as employees/consultants to state agencies to advocate for:
- clearly defined roles and responsibilities understood by supervisors and colleagues,
- appropriate accountability measures for SLPs and audiologists in education settings,
- suitable workloads to ensure the provision of high-quality services that meet the needs of clients with communication impairments.