Narratives for ASHA's 2012 Public Policy Agenda

1. The Elementary and Secondary Education Act (ESEA) does not currently authorize funding for speech-language pathology or audiology services. Hence, most school districts do not utilize those funds to support students with communication impairments. Funding for those services are most typically provided by federal, state, and local special education funds. ASHA supports the utilization of ESEA and other funding sources to adequately support students with communication impairments at a very early age and to implement service provision models within general education as part of early intervening services or a response to intervention model.
2. With the federal deficit crisis, ASHA will advocate for maintaining the current funding level for the Individuals with Disabilities Education Act (IDEA) to support members who provide early intervention and school services. Additionally, early intervention services were traditionally clinic-based, while school service delivery options typically have been relegated to pull-out direct service, often once or twice weekly. ASHA has promoted a variety of early intervention and school-based models as effective practices designed to increase service delivery efficiency and positive outcomes for children and youth.
3. Speech-language pathologists (SLPs) and audiologists have traditionally worked with students who qualify for special education services under IDEA Part B and C. The paperwork burden associated with service delivery for special education students is significant and creates challenges for recruiting and retaining personnel. Innovative strategies for addressing this paperwork burden are needed. For example, IDEA 2004 (Part B) opened the door for SLPs and audiologists to work with students in the general education population under the guise of early intervening services. In addition, if state special education funding allows SLPs and audiologists to provide services outside of special education (e.g., speech instruction or similar) paperwork burden can frequently be decreased by serving students in these models instead of special education. (While paperwork burden is critical in education, it is also problematic in health care and other settings.)
4. Poor classroom acoustics impact learning for all children, but the effects are especially pronounced for those with hearing loss, speech or learning impairments, as well as those who learn English as a second language. The U.S. Access Board is in the rule-making process to address acoustics in classrooms by incorporating ANSI/ASA S12.60 Classroom Acoustics Standard into the ADA and ABA Accessibility Guidelines. ASHA will work to ensure that the classroom acoustic standards are adopted so that newly constructed or significantly renovated school buildings provide an appropriate learning environment for all students.
5. Audiology services are currently categorized by Centers for Medicare and Medicaid Services (CMS) as diagnostic-only. This means that services, such as aural and vestibular rehabilitation, as well as tinnitus management, can only be reimbursed under Medicare when provided by another discipline. ASHA will promote reimbursement for the entire spectrum of audiological services including diagnosis and rehabilitation along with an opt-out provision. Opting-out allows those audiologists to choose whether or not to participate in the Medicare program.
6. Speech-language pathologists and audiologists face ongoing challenges related to reimbursement for their services, from both public and private payers. Additionally, some insurance carriers continue to promote exclusionary policies for specific diagnoses served by both professions. ASHA will continue to monitor these policies and reimbursement rates to ensure that speech-language pathologist and audiologists are reimbursed fairly for the services they provide.
   
   The Centers for Medicare and Medicaid Services (CMS) is engaged in both short and long-term studies to develop a payment policy to replace the therapy caps. ASHA is an active stakeholder in these efforts. Until an appropriate alternative is identified and approved by Congress, ASHA will continue to support the extension of the therapy cap exceptions process. Furthermore, without an alternative the current budgetary constraints and congressional interest in an alternative, make repeal of the caps an unviable solution.
7. Some insurance companies exclude habilitative speech, language, and hearing services and equipment while they may cover rehabilitative services. ASHA seeks to ensure comprehensive insurance coverage of habilitative services as these are critical to the attainment of positive health outcomes for individuals with developmental rather than acquired disabilities.
8. More than 12,000 infants are born with hearing loss annually. Data from EHDI reveal that 97% of all infants have documented hearing screenings at birth. Of those with a diagnosed hearing loss, 34% were either lost to follow-up or lost to documentation. Implementation of the reauthorized EHDI program should emphasize follow-up to newborn hearing screening, including the diagnosis, appropriate referrals to early intervention programs, treatment, and family support services for children with hearing loss. In addition, advocacy is needed to expand insurance coverage of hearing aids, cochlear implants, and related devices and services.
   
   Recently released research found that 19.5% of children ages 12–19 had some kind of hearing loss. This is an increase from 14.9% covering the years 1988 to 1994 and has focused attention on the prevention of noise-induced hearing loss, especially when caused by using earbuds with personal music players. (While this issue primarily falls in healthcare, education and other settings are also impacted.)
9. Promoting universal licensure using the CCC as the benchmark for qualifications would support consistency across states, allowing for reciprocity and would help address issues of competing standards across settings. Universal licensure would also eliminate the need for school practitioners to hold multiple credentials to practice in the education environment which can lead to confusion with conflicting continuing education and other maintenance requirements.
10. ASHA seeks to develop and disseminate model language for states that explicitly define the credentials, competencies, and service delivery options for CCC SLPs and SLP-Assistants in an effort to support delivery of quality services to individuals with communication disabilities. Many states have already implemented alternative credentialing systems to allow other professionals or support personnel to provide services to students with speech, language, and hearing disorders. The SLP summit convened by ASHA in July 2011, offered several recommendations, including the development of a continuum of service providers. Results of the summit were presented to the ASHA Board of Directors who has charged a summit sub-committee with review of the recommendations and identification of action items for staff and members to implement.
11. Strategies to support recruitment and retention include financial aid, loan forgiveness, salary supplements, workload models, and research funding opportunities. Loan forgiveness for those working in all settings could potentially increase recruitment of students for the field and increase the availability of PhD research and teaching faculty as well as clinical practitioners. Financial supports and other recruitment strategies also need to be implemented to increase diversity of individuals seeking master's and doctoral degrees, including bilingual clinicians and researchers.
12. Medicaid is a federal-state matching medical assistance program, with funds allocated to each state to match state expenditures for the cost of medical assistance. The dollars are administered by Centers for Medicare and Medicaid (CMS), which also approves every state Medicaid plan. Medicaid recognizes the importance of speech-language and audiology services in early intervention and public schools, and allows for reimbursement for children with disabilities who receive health-related services through an Individualized Family Service Plan (IFSP) or Individualized Education Program (IEP). This reimbursement is not "double-dipping" as IDEA funding is not sufficient to fully cover the cost of these services. Early intervention providers and schools pay for these services with state and local dollars and only receive Medicaid reimbursement for a portion of the costs.
    
    Eligibility for special education services requires that the disability impacts educational performance. Not all students with speech-language disorders require an ISFP or IEP and not all speech-language or audiology services included in the IFSP or IEP may be medically necessary. Each Medicaid state plan defines the requirements of medical necessity. Only those services in the IFSP or IEP that meet the requirements of medical necessity can be billed to Medicaid.
    
    Receiving services through early intervention or the schools does not preclude students who require speech-language or audiology services from receiving services in other environments and billing Medicaid for these services. Some children who do not qualify for services through early intervention or the schools may require services in other environments.
13. The Government Pension Offset (GPO) and Windfall Elimination Provisions (WEP) reduce social security benefits for public sector employees who are in non-social security retirement systems, including many teacher retirement systems throughout the country. Speech-language pathologists who work in the schools are frequently part of these non-social security retirement systems. Any social security benefits to which they are entitled will be reduced if/when they draw benefits from the non-social security teacher retirement system. This creates a disincentive for individuals to work in different settings, schools, and other environments, because their retirement benefits will be negatively impacted. ASHA will continue to work with other groups to support modification of these laws.
14. State agencies (e.g., education, health) support legislative, regulatory, technical assistance, and professional development needs to local agencies and organizations. Speech-language pathologists and audiologists as employees of those agencies or as consultants to those agencies can influence current and pending legislation, regulations, and licensure requirements; support and/or implement technical assistance and professional development activities to promote evidenced based practices; and initiate other activities to improve outcomes for individuals with communication disabilities. ASHA networks that can be instrumental in these initiatives include State Education Advocacy Leaders (SEALs), State Advocates for Reimbursement (STARs), and State Medicare Administrative Contractors (SMACs).
15.  Telepractice is an emerging health care service-delivery model that utilizes technology to efficiently provide diagnosis or treatment from a distance. Speech-language pathologists and audiologists provide a wide range of services that can be delivered effectively using telepractice methods and technology. ASHA will continue to promote increased technology infrastructure, reimbursement, and credentialing of providers for telepractice services in health care and educational settings.
16. Continued basic and applied research in speech, language, and hearing science are essential for the long-term viability of the professions, as well as demonstrating the effectiveness and importance of the services provided by ASHA members. ASHA will continue to advocate for increased research funding and support members who seek support through a wide range of funding mechanisms and agencies.
17. Consistent with ASHA's vision, mission, and role as a leader in the area of human rights, support of laws that promote non-discrimination will protect and address the increasing diversity of ALL of ASHA's membership, as well as the student populations, and the clients/patients we serve.