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On April 24, 2006, the California Attorney General issued an opinion ruling that the credential issued by the California Commission on Teacher Credentialing as a Speech-Language Pathologist-Clinical or Rehabilitative Services Credential-is not equivalent to the ASHA Certificate of Clinical Competence (CCC) for the purposes of Medicaid reimbursement. Under federal regulation 42 CFR 440.110, in order to qualify for Medicaid reimbursement, services must be provided "by or under the direction of a speech-language pathologist or audiologist." The regulation then goes on to define a speech-language pathologist as an individual who has a Certificate of Clinical Competence from ASHA or has completed the equivalent educational requirements and work experience necessary for the certificate or has completed the academic program and is acquiring supervised work experience to qualify for the certificate.
It is the policy of the Centers for Medicare and Medicaid Services (CMS) to require an official state attorney general's opinion on the equivalency of any state credential to the ASHA CCC before ruling that services provided by an individual with that credential are reimbursable under Medicaid. The California Attorney General's ruling means that the California teacher credential is not sufficient to qualify services for Medicaid reimbursement.
The California school credential requires only a master's degree from a regionally accredited college or university and passage of the California Basic Educational Skills Test. The school credential does not require that the master's degree be obtained from a Council of Academic Accreditation (CAA)-approved program nor does it require a clinical fellowship or passage of the Praxis exam. ASHA submitted a formal letter to the California Attorney General's office detailing the differences between the California school credential and the ASHA CCC. In addition, ASHA staff worked closely with the state attorney general's office to explain the intricacies and nuances of ASHA certification and the differences between the two credentials.
For more information, please contact Susan Pilch, ASHA's Director of State Legislative and Regulatory Advocacy, by e-mail at spilch@asha.org or by phone at 800-498-2071, ext. 4284.
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