2016 ASHA Public Policy Agenda: Summaries
The following issues are managed at the federal level, and each issue objective bullet is ranked in importance based on member responses to the survey.
Medicare Reimbursement and Coverage Policies
ASHA members who treat Medicare beneficiaries constantly face the challenges within an increasing complex Medicare system. Reimbursement for services will be affected by changes to the Medicare Part B payment system that call for value-based purchasing and evidence-based practice, heightened economic restrictions, issues related to bundling, and implementation of the Affordable Care Act. Changes to the valuation of procedural codes will continue to challenge the reimbursement of service delivery. Furthermore, the emergence of managed-care trends that emphasize physician-directed care models could result in challenges to clinical judgement and affect the dynamics of coordinated care. Interprofessional practice models will continue to emerge, which situation would require advocacy to ensure that audiologists and SLPs are recognized as valued and integral members of the health care team.
- advocate for equitable inclusion/reimbursement for audiologists and SLPs, as well as coverage of services and devices for beneficiaries of Medicare health plans;
- represent both audiologists and SLPs (a) before the Centers for Medicare & Medicaid Services to ensure the maintenance and/or expansion of appropriate values, coverage, and reimbursement rates and (b) on the American Medical Association coding committees;
- promote an alternative payment policy for Medicare outpatient therapy services to eliminate the reimbursement cap placed on rehabilitation services;
- support Medicare coverage of audiologic diagnostic and treatment services;
- support implementation of Medicare Part B payment reforms;
- support opt-out of the Medicare program for audiologists and SLPs;
- monitor industry trends and advocate to ensure that less qualified providers are not being employed as cost-saving measures to provide audiology and speech-language pathology services.
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 and Secondary Education Act (ESEA, aka No Child Left Behind), and the Higher Education Act (HEA). In 2016, Congress is expected to reauthorize ESEA followed by HEA. Survey respondents ranked the bullets pertaining to IDEA reauthorization high; unfortunately, it is not anticipated that serious congressional consideration of IDEA will occur in 2016.
- support inclusion of audiologists and SLPs in literacy programs and professional development funding during conference negotiations related to ESEA reauthorization; support provisions that allow for greater flexibility for use of general education funds for at-risk children in general education (e.g., response to intervention);
- seek opportunities to include audiologists and SLPs in HEA provisions;
- advocate for reauthorization of IDEA to maintain funding of the program, flexibility of funding, appropriate use and reimbursement of audiologists and SLPs, inclusion of highest qualified provider requirements, provisions to address paperwork burden, Part B loan forgiveness, and any other relevant provisions related to Part B, C, and D or IDEA;
- support consistent language and common terminology for specialized instructional support personnel (SISPs; including audiologists and SLPs) in IDEA and ESEA and use of the term highest qualified provider in IDEA;
- 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;
- support federal legislation that includes audiologists and SLPs as a part of student athlete concussion management teams.
Federal and State Levels
The following issues are managed at both the federal and state levels, and each issue objective bullet is ranked in importance based on member responses to the survey.
Funding and Practice Issues for School-Based and Early Intervention Services
School-based audiology and speech-language pathology programs are affected by staff shortages, increased paperwork, funding cuts, greater workload/caseload demands, and changing delivery models and standards (e.g., Common Core State Standards, Response to Intervention). Threats to the provision of early intervention services include reduced funding and difficultly obtaining reimbursement, scope of practice issues, and constraints of providing services. These result in uncertainties for members and threaten to undermine their ability to provide effective services to children.
- educate and support state associations and member advocacy efforts with administrators and decision makers regarding workload/caseload management;
- seek alternatives to help reduce the paperwork and administrative burden on school-based audiologists and SLPs based on recommendations of the Government Accountability Office study of paperwork and subsequent congressional action;
- oppose cuts in education funding;
- promote state and local adoption of appropriate accountability/evaluation measures (e.g., Performance Assessment of the Contributions and Effectiveness of SLPs) for audiologists and SLPs;
- advocate for states and local agencies to implement IDEA Part C Infants & Families Program requirements and ensure appropriate use of audiologists and SLPs in the identification and treatment of children in early intervention programs;
- advocate for appropriate and timely reimbursement for early intervention services;
- advocate for increased funding for Part C services;
- advocate with states and local agencies to implement federal standards related to IDEA Part B and ESEA;
- advocate for audiologists and SLPs to be included as part of the diagnostic, intervention, and management teams for students engaged in athletic activities.
Hearing Health Care
Hearing loss is under identified, resulting in unmet medical needs across the life span. Federal and state legislative and regulatory agencies are exploring opportunities to address the issue. ASHA understands the problems of access, diagnosis, and treatment of individuals with hearing impairment. There has been an increase in the use of hearing aid dispensers, which may compromise the effectiveness of patient care.
- promote a comprehensive system of children's hearing health care services, including state hearing screening standards; insurance coverage of hearing aids, cochlear implants, implantable hearing devices, and other related devices and equipment; and diagnostic and treatment services for children;
- support hearing aid tax credit legislation to increase affordability of hearing aids;
- support legislative and regulatory efforts related to classroom acoustics;
- 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;
- address the Food and Drug Administration's regulations and guidance documents related to Internet and retail sales of hearing aids, personal sound amplification products (PSAPs), and general wellness products;
- address the Federal Trade Commission's oversight of deceptive advertising by sellers of PSAPs;
- advocate for consumer access to safe and effective hearing health care services, devices, hearing aids, and environments;
- oppose efforts by hearing aid dispensers to increase their scope of practice as health care providers within state and federal programs, such as the Veterans Health Administration programs;
- monitor and provide feedback to the Institute of Medicine and other entities on hearing policies.
Medicaid Reimbursement and Coverage Policies
Medicaid programs—a federal/state partnership implemented based on state priorities—impact both health care and school-based providers. ASHA members will continue to see significant changes in the Medicaid requirements for value-based purchasing and evidence-based practice, economic restrictions, expansions of managed care, issues related to bundling, and implementation of the Affordable Care Act. These factors will play a significant role in the reimbursement of audiology and speech-language pathology services. Medicaid requirements for reimbursement have created unique challenges for providers in clinical, health care, and education settings.
- advocate for coverage and adequate reimbursement of services provided by audiologists and SLPs;
- 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;
- advocate for access to audiology and speech-language pathology services through the federally mandated Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit and state requirements for health care and school settings;
- advocate for appropriate policies, guidance, and regulations related to Medicaid covered services in schools and other settings.
Patient Protection and Affordable Care Act (ACA)
States are continuing to face the challenges of implementing the ACA's requirements. ASHA will continue to advocate and offer support to state associations for adoption of the ACA requirements, including insurance coverage of essential health benefits as implemented through regulations.
- advocate for reimbursement policies that include habilitative and rehabilitative services in private health care plans and programs of other stakeholders;
- advocate for the role of the professions of audiology and speech-language pathology in service delivery models, such as Accountable Care Organizations and coordinated care;
- advocate for appropriate state implementation of ACA requirements for essential health benefits;
- advocate with the Center for Consumer Information and Insurance Oversight (CCIIO) for federal monitoring and enforcement of essential health benefits;
- give members information and support that facilitate both a federal and state understanding and implementation of best practices to ensure appropriate inclusion of habilitative and rehabilitative services.
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.
- continue to advocate for coverage and adequate reimbursement for services and devices provided by audiologists and SLPs and provide input to coverage policies in private insurance plans;
- advocate for consumers and providers through the appeals process with private insurance providers and insurance commissioners, which may result in coverage changes for all participants.
Telepractice is an appropriate model of service delivery for the professions of audiology and speech-language pathology when services are equivalent to those provided face to face. Telepractice may be used to overcome barriers to individuals' accessing and receiving services.
- advocate for the recognition and coverage of appropriate services delivered through telepractice and, if necessary, ensure that such legislation includes appropriate licensing standards;
- advocate for coverage—by Medicare, Medicaid, and other federal agencies/programs, as well as private health plans—of telepractice services through federal and state legislation and regulation;
- advocate for state requirements that ensure consumer protection when telepractice services are provided by audiologists and SLPs.
Loan Forgiveness/Tuition Assistance as a Recruitment and Retention Tool
ASHA supports strategies to increase recruitment and retention of audiologists and SLPs through financial aid and loan forgiveness. Some states, including Mississippi and Texas, have passed loan forgiveness legislation specifically for SLPs.
- continue to support state legislative efforts to adopt loan forgiveness and tuition assistance provisions for audiologists and SLPs;
- monitor federal incentives and loans.
Demonstrating Value and Quality of Services
Consumers and decision makers across settings are increasing their demands for evidence-based interventions and quality outcomes. The use of outcomes data and quality indicators demonstrates the value of audiology and speech-language pathology services in all settings.
- take the leading role in establishing policies that define quality and desired outcomes of audiology and speech-language pathology services and reflect the needs of the clients and professions;
- empower members and state association leaders to advocate with payers, school administrators, and/or consumers regarding the value and expertise of audiology and speech-language pathology services;
- develop clinical data registries to support advocacy efforts related to adequate reimbursement across payers;
- support recognition of the ASHA CCCs and advocate for policies that require use of the highest qualified provider;
- engage, inform, and collaborate with other professionals to provide comprehensive, integrated services.
Scope of Practice
The clinical practice of other providers without audiology or speech-language pathology credentials infringes on the scope of practice and clinical expertise of audiologists and SLPs.
- oppose practice acts and licensure efforts that would expand the scope of practice of other professionals and practitioners (e.g., music therapists, ABA therapists, developmental therapists, dyslexia therapists) into the scope of SLPs;
- oppose efforts of hearing aid dispensers to expand their scope of practice in areas in which they are less qualified and under educated; the success of such efforts would compromise quality of client care.
The following issues are managed at the state level, and each issue objective bullet is ranked in importance based on member responses to the survey.
State regulatory agencies create unnecessary barriers by requiring members to obtain and maintain multiple licenses and/or certifications. Many states require audiologists to hold a separate license to dispense hearing aids. Some states have issued a comprehensive (single) license for SLPs, allowing them to practice in any setting, and 40 states allow audiologists to dispense hearing aids with a single license with some exceptions (e.g., passing an exam, completing a training program, or registering with the hearing aid dispensing board).
- support legislation and regulations that allow audiologists to dispense hearing aids under a single license;
- support comprehensive licensure for SLPs that is recognized by state credentialing agencies and ensures maintenance of existing benefits.
Audiology and Speech-Language Pathology Assistants Within the Service Continuum
Given the shortage of audiologists and SLPs, 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.
- advocate for state regulations, including education, training, and supervision requirements, for audiology assistants and SLPAs;
- promote the delivery of quality services to individuals with communication disorders;
- explore ways to demonstrate basic competencies of audiology assistants and SLPAs.
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. In some states, audiologists and SLPs are hired as consultants to help members in the state 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 SLPs as consultants to DOEs;
- provide departments of education with information about the importance of audiology and speech-language pathology services;
- promote the retention of qualified audiologists and SLPs who are currently serving as employees/consultants to state agencies.