2014 ASHA Public Policy Agenda: Summaries
The following issues are 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 cap reimbursement on speech and physical therapy services. Audiologists must contend with the lack of comprehensive coverage of services, specifically including treatment services. Both audiologists and SLPs seek fair compensation for their services and the ability to opt-out of the Medicare program. Opt-out is the right to establish private contracts between the audiologist or SLP and the Medicare beneficiary outside of the Medicare system. 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 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 treatment services as well as the right of audiologists to opt-out of the Medicare program;
- support the right of speech-language pathologists to opt-out of the Medicare program;
- represent both audiologists and SLPs before the Centers for Medicare & Medicaid Services to ensure the maintenance and/or expansion of appropriate values, coverage, and reimbursement rates including representation on the AMA Coding Committees.
Reauthorization of Federal Education Legislation
Federal law provides guidance related to the roles, responsibilities, and funding of school-based services. The three major federal education laws are the Individuals with Disabilities Education Act (IDEA), the Elementary & Secondary Education Act (ESEA, aka No Child Left Behind), and the Higher Education Act (HEA). ASHA will:
- advocate for reauthorization of IDEA and ESEA and promote the inclusion and funding of speech, language, literacy, and hearing services and devices in all federal legislation;
- support consistent language and common terminology, including the use of the term highest qualified provider in IDEA and ESEA;
- seek opportunities to include SLPs in federal literacy policies;
- seek opportunities to include audiologists and SLPs in HEA provisions.
Federal and State Level
The following issues are managed at both the federal and state levels.
Funding and Practice Issues for School-Based Services
The climate of school-based audiology and speech-language pathology is characterized by staff shortages, increased paperwork, and greater workload and caseload demands. The implementation of sequestration has led to decreased budgets at the federal, state, and local levels. This results in uncertainties for school-based members and threatens to undermine their ability to provide effective services to children. To support our members in school settings, ASHA will:
- promote adoption of appropriate accountability/evaluation measures for specialized instructional support personnel (SISPs) in educational 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 audiologists and SLPs;
- advocate with states to implement federal standards related to IDEA Part B and ESEA;
- 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 align with the needs of ASHA's school-based members and graduate academic programs.
The United States has seen an overall increase in the number of individuals with reported hearing loss. Consequently, there is greater need-and demand-for appropriate professional audiology and speech-language pathology services 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. ASHA will:
- support hearing aid tax credit legislation to increase affordability of hearing aids;
- Food and Drug Administration (FDA) regulations and guidance documents related to Internet and retail sales of hearing aids and personal sound amplification products (PSAPs);
- Federal Trade Commission (FTC) oversight of deceptive advertising by sellers of PSAPs;
- support 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;
- promote 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, implantable hearing devices and other related devices, equipment, and diagnostic and treatment services for children.
Medicaid Reimbursement and Coverage Policies
ASHA members will see significant changes in the Medicaid program due to health care mandates in the Patient Protection and Affordable Care Act (ACA) and federal initiatives related to entitlement reform. To help ASHA members, we will:
- advocate for coverage of services provided by audiologists and SLPs, including maintaining funding for services mandated by the federal Early and Periodic Screening, Diagnosis, and Treatment (EPSDT) program, ensuring that services are based on the needs of the individuals served, and establishing reasonable beneficiary eligibility requirements in traditional Medicaid and Managed Care Organizations;
- advocate for appropriate policies and regulations of Medicaid covered services in schools and other settings;
- promote reimbursement for devices, including but not limited to hearing aids, cochlear implants, other implantable devices and related equipment, and augmentative and alternative communication (AAC) devices.
Patient Protection and Affordable Care Act (ACA)
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. ASHA will:
- advocate with the Center for Consumer Information and Insurance Oversight (CCIIO) for federal monitoring and enforcement of essential health benefit requirements for coverage of habilitative and rehabilitative services and devices;
- advocate for appropriate coverage of habilitative and rehabilitative services and devices within state health insurance exchanges;
- advocate for the role of audiology and speech-language pathology in emerging service delivery models such as Accountable Care Organizations and coordinated care.
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 audiologists and SLPs and provide input to coverage policies in private insurance;
- assist members with insurance appeals for medically necessary services.
Telepractice is an appropriate model of service delivery for the professions of audiology and speech-language pathology. See ASHA's Telepractice website. It may be used to overcome barriers of access to services. ASHA will:
- advocate for the recognition and coverage of appropriate services delivered through telepractice, see ASHA's Telepractice website;
- advocate for Medicaid coverage of appropriate services delivered;
- monitor opportunities to advocate for funding through federal and state legislation and regulation with private health plans
The following issues are managed at the state level.
Loan Forgiveness as a Recruitment and Retention Tool
ASHA supports strategies to increase recruitment and retention of audiologists and SLPs through financial aid and loan forgiveness. We will continue to support state legislative efforts to adopt loan forgiveness provisions for audiologists and SLPs.
State regulatory agencies create unnecessary barriers by requiring members to obtain and maintain multiple licenses and/or certifications depending on practice setting. Many states have recognized the advantage of issuing a single license for audiologists or SLPs to practice. ASHA will continue to advocate for a comprehensive (single) license for each profession in each state, which would allow members to practice in any setting and improve licensure portability across states.
With the shortage of audiologists and SLPs, more and more states seek options for identifying 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 audiologists, SLPs, speech-language pathology assistants (SLPAs), and audiology assistants. ASHA will:
- advocate for state regulations including education, training, and supervision requirements to promote uniform standards for the full continuum of audiology and speech-language pathology service providers;
- promote the delivery of quality services to individuals with communication disorders;
- explore ways to demonstrate basic competencies of audiology assistants and speech-language pathology assistants.
State departments of education (DOE) and/or state education agencies hire individuals to implement DOE policies, assist with educator questions, and provide training and support to the field. In some states audiologists and SLPs are hired as consultants to assist members in the state to help meet DOE requirements. With increased demands on state budgets, fewer audiology and speech-language pathology consultants are being hired and/or retained. ASHA, in collaboration with state associations and organizations, will:
- support member efforts and states seeking qualified audiologists and speech-language pathologists as consultants to the DOE;
- promote the retention of qualified audiologists and SLPs who are currently serving as employees/consultants to state agencies.