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Keep in mind that many private health plans and state Medicaid programs selectively adopt Medicare coverage policies.
Medicare Supervision of Students. In 2001, the Centers for Medicare and Medicaid Services (CMS) determined that student-assisted outpatient (Part B) speech-language pathology and audiology services are covered only when the "qualified practitioner is present and in the room for the entire session…directing the service, making the skilled judgment, and is responsible for the assessment and treatment" and "is not engaged in treating another patient or doing other tasks at the same time." For Part A services in a skilled nursing facility, the patient and the student must be within line of sight of the supervisor. There are no specific rules for other Part A settings. While students may enter notes in the patient's medical record and sign them, the supervisor's counter-signature is always required.
Medicare Supervision of Clinical Fellows. A clinical fellow (CF) is fully qualified under Medicare if state-licensed. Many states issue temporary, provisional, or interim licenses to CFs. For those states in which licensure is not granted to CFs, there may be a predicament because Medicare (1) does not consider the CF a student and (2) does not cover speech-language pathology or audiology services rendered by support personnel or assistants.
State Medicaid Programs
Students: Each state is free to adopt its own policy regarding coverage of services by students.
Clinical Fellows: Federal Medicaid regulations consider CFs fully qualified, thus no additional supervision requirements apply. If a state requires licensure to practice but does not allow licensure of CFs, the CF services could be covered under the federal Medicaid regulation that allows services to be rendered "under the direction of" a qualified SLP or audiologist. Although each state is free to determine the supervisory conditions for "under the direction of," CMS has outlined its expectations, which include the supervisor's responsibility to be familiar with each case, and see the patient at the beginning of treatment and periodically throughout. The expectation is that supervisors take professional responsibility for services provided under their supervision.
—Mark Kander, ASHA's director of Health Care Regulatory Analysis
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