| Old Medicaid Regulation |
ASHA Policy Position |
New CMS Regulation |
| 42 CFR 440.110 (c)(2): |
ASHA urged CMS to: |
Federal Register Notice: |
| Combined speech-language pathologist and audiologist standard |
Recognize audiology as an autonomous and distinct profession |
New separate section for audiologist qualifications |
| CCC-A |
Standards in all state licensing laws and regulations for Medicaid population, equal to or greater than CCC-A |
State license for audiologists, providing that the state licensure requirements meet or exceed the CCC-A or the Medicare statutory definition (1993 CCC-A standards) |
| Or equivalent educational requirements and work experience |
Tighten loophole in equivalency clause that has allowed lesser-qualified providers to bill directly for Medicaid audiology services |
In states that lack licensure, have lesser licensure standards , or exempt audiologists practicing in specific settings (such as schools), audiologists need the CCC-A or Medicare statutory definition (1993 CCC-A standards) |
| Supervision guidance absent for lesser-qualified providers "under the direction of" audiologist |
Strengthen "under the direction of" guidance to ensure that only audiologists provide or supervise audiology services for Medicaid beneficiaries |
Audiologist responsible for providing or supervising each beneficiary's care. Audiologist to initially evaluate patient, prescribe treatment, and review the need for continued services. Requires contractual or other formal agreement that outlines supervision.
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