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COVID-19: Guidance for Graduate Programs, Students, and Clinical Fellows

From the Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC)

The CFCC will continue to monitor this unfolding situation. Please note that this page will be updated frequently and any dates (noted with *) will be adjusted accordingly.

Updated March 30, 2020

The world is a much different place than it was a matter of weeks ago, and we have all been affected professionally and personally by COVID-19. We acknowledge that you, your students, Clinical Fellows, and clients/patients/students are going through a very uncertain and difficult time. We especially sympathize with the students and Clinical Fellows who have been working for several years to take the next steps in their careers in the upcoming months. The CAA and CFCC recognize that you are doing everything in your power to maintain the integrity of your programs, comply with accreditation standards, and support students in meeting the requirements for certification.

As mentioned previously, this is an unprecedented situation that is affecting the ability for clinical services to be provided on site and in person with clients and patients as required by the 2020 Audiology and Speech-Language Pathology Certification Standards. This situation extends to the ability for graduate student clinicians and Clinical Fellows to be physically present with clients/patients.

The CFCC understands these concerns and is continuously monitoring the situation and working with the CAA to identify options for CAA-accredited programs to help their graduate students to meet the minimum 400 clinical practicum hours in accordance with the standards. After careful consultation with the CAA, the CFCC is unable to reduce the number of clinical practicum hours since programs not only need to meet ASHA Certification standards but also those required by state or federal organizations, such as state licensing boards, the U.S. Department of Education, and the Council for Higher Education Accreditation (CHEA). The CFCC has jurisdiction over what is required for the purposes of ASHA certification; however, ASHA does not have jurisdiction over these external agencies/bodies. 

Similarly, due to state licensing requirements that mirror ASHA certification standards, the minimum number of hours (1,260) and weeks (36) for Clinical Fellows will remain the same. The CFCC wants to provide clarification about several frequently asked questions and explain allowances that have been made for graduate programs/graduate student clinicians and Clinical Fellows.

Graduate Programs and Graduate Students

CAA and CFCC rationale for maintaining clinical education requirements:

  • The CAA and CFCC have responsibility to assure stakeholders that graduates, Clinical Fellows, and certificate holders are clinically competent to practice. The accreditation and certification standards have been developed and refined throughout the years by undergoing a vigorous vetting process to protect the public, students, and payers. These standards ensure standardization in the amount and quality of education and training that students receive prior to beginning their Clinical Fellowship (CF) and that a Clinical Fellow receives before practicing as an independent clinician.
  • Reducing standards could pose potential risks to students and Clinical Fellows who (1) may not be competent and/or qualified to practice as those who were educated and trained before them or those who will be educated or trained in the future, (2) may not be able to meet state licensure or insurance requirements, and (3) most importantly, would put clients/patients/students at risk.
  • The CFCC has received many inquiries related to expanding the use of clinical simulations to supplement direct client/patient experience, which the CFCC rejected. As you may be aware, the standards already allow for up to 75 hours to occur at the undergraduate level (25 hours of observation and 50 hours of supervised clinical practicum) and for 75 hours to be acquired through clinical simulations, which means only 250 hours of the 400 hours of clinical practicum have to come from direct client/patient care if all allowances are used, which currently can be done through telepractice. The CFCC believes these 250 hours are necessary to ensure students are ready to begin their CF experience.
  • It has also been requested that the CAA and CFCC lower the total amount of clinical practicum required for graduation/certification and roll those hours into an extended CF. This was also rejected because it (1) does not comply with the range of state credentialing requirements across the country and (2) has the potential to endanger client/patients/students.
  • We understand that several states do not permit the use of telepractice; however, given the current environment and need for healthcare services, many of those states are considering emergency legislation to permit for telepractice. If you have questions about telepractice within your state please contact your state licensure boards or visit the ASHA site for state-by-state regulatory information on telepractice and temporary practice.
  • To assist all stakeholders, the CFCC has made a variety of accommodations over the past two weeks which allow hours/experience to be counted for ASHA certification in ways which were previously not allowed. The CFCC’s initial timeframe for these accommodations is from March 16 – April 30, 2020. Given how this situation continues to evolve, the CFCC has extended these accommodations nationwide through May 31, 2020, and will consider future extensions as needed.
  • During this time, academic programs are encouraged to find ways to accommodate various methods for students to meet the standards, such as distance education, tele options, program extensions, etc.

Clarification of Frequently Asked Questions

The CFCC will continue to support programs as they outline plans to ensure that their students are meeting certification standards. As such, the CFCC wants to clarify the following:

  • ASHA Audiology Certification Standards refer to CAA standards for the amount of clinical practicum required for audiology student clinicians.
    • CAA standards require a minimum of 12 months of full-time equivalent experience that occurs throughout the duration of the graduate program.
      • “Short” and “long” experience that occur in years 1–3 may be applied for the purposes of ASHA certification.
      • If all hours are not obtained under the supervision of a CCC-A, applicants may complete this post-graduation in accordance with the standards.
    • Audiology students may earn up to 10% of their clinical practicum experience thorough clinical simulation.
    • Telepractice and telesupervision may be used to obtain the required supervised clinical practicum, as stated in Standard III of the 2020 Standards.
  • ASHA SLP Certification Standards require a minimum of 400 clinical practicum hours for SLP graduate student clinicians.
    • The standards state that applicants for certification must demonstrate competence in the areas outlined in Standards IV and V, however the programs are given flexibility in how students demonstrate competence. The standards do not specify the minimum number of sites, adults vs pediatric hours, or contact with each specific client/patient population required to demonstrate competence. Programmatic or state licensure requirement may be more specific.
    • 25 hours are obtained through guided observation. ASHA does not limit the number of observation hours earned through video recordings.
    • 375 hours are obtained through supervised clinical practicum.
      • 325 of these hours must be earned while the student enrolled in a graduate program.
      • The graduate program may count up to 50 hours of supervised clinical practicum that were completed within the undergraduate program.
      • Up to 75 hours may be obtained through clinical simulation (CS) activities. The CFCC is not adjusting the maximum number of hours permitted through CS. Programs have the authority to determine how best to debrief students and determine what documentation is required.
      • A minimum of 250 hours of supervised clinical practicum within the graduate program are required in instances where the graduate student earns 75 hours through CS, 50 hours during undergraduate clinical practicum, and 25 hours through guided observation. These remaining 250 hours are obtained through direct clinical contact with clients/patient.
      • From March 16 – May 31, 2020,* telepractice and telesupervision may be used to obtain the required supervised clinical practicum. It is up to the discretion of the graduate program to determine how many hours can be earned through telepractice. See below for additional accommodations.
  • Grading
    • Neither ASHA certification nor accreditation standards set grading requirements. This includes pass/fail or satisfactory/unsatisfactory options.
    • Grading is up to the discretion of the program and must be in accordance with university policies and procedures.
  • Praxis examination
    • The certification standards for both professions require that a passing exam score be earned no earlier than 5 years prior to the submission of an application and no later than 2 years following receipt of the application.
    • Passing this examination prior to graduation may be a programmatic requirement.

CFCC Allowances

The CFCC has made some allowances for graduate student clinicians in CAA-accredited programs. Please note that consideration must be given first to students who are scheduled to graduate in the 2020 spring and summer semesters.

Telepractice with Telesupervision: From March 16 – May 31, 2020, graduate student clinicians in both professions who are enrolled in CAA-accredited and CAA-candidacy programs may engage in service delivery through telepractice when the clinical educator provides 100% direct supervision of the sessions in real time.

  • Program and clinic directors have the authority to determine how many students can appropriately take part in an online teletherapy session with one client. Multiple students may participate in the same session. Each student will earn the full hour toward the completion of their clinical practicum.
  • Programs must carefully consider which clients/patients are appropriate for telepractice. As always, programs must adhere to all local/state/federal policies.
  • It is up to the discretion of each program to determine how many hours may be earned through telepractice. There currently is no cap for the purposes of ASHA certification. These hours are separate from the hours earned through clinical simulation.
  • Why is 100% supervision required?
    • Guidance for supervision of graduate students is state-specific, and some states require 100% supervision in certain settings. Some states also have additional rules for in-person supervision vs telesupervision. In order to make this option available to as many programs as possible, the CFCC must continue with the 100% telesupervision requirement for students participating in telepractice.
    • 100% student supervision is required for in-person services delivered to some older adults while billing Medicare Part B. Since telepractice with graduate student clinicians is not addressed in the recent changes from CMS, programs are encouraged to ensure that they are in compliance when providing services to their older client who could be a Medicare beneficiary.
    • For the purposes of ASHA certification, student clinicians, clinical educators, and clients/patients/students are permitted to be in their own (separate) locations. However, some states or payors could possibly consider that students working through telepractice from their own locations with less than 100% telesupervision are practicing independently since they are not within close range of a fully licensed and certified CCC-SLP.
      • For the protection and safety of clients/patients and for student clinicians, many of whom have never used nor have been trained in telepractice as a service delivery model and are all in separate locations, the CFCC has required 100% telesupervision.

Speech-Language Pathology Clinical Fellows

The CFCC is getting many questions about CF experiences in light of the closures and cancellations due to COVID-19. Last week the CFCC provided an allowance for Clinical Fellows to accumulate CF experience weeks/hours through telepractice from March 16 – May 31, 2020.* However, the CFCC understands that telepractice is not an option in all CF settings, so we have provided the additional guidance and tips below to help Clinical Fellows continue their CF experience, even if they cannot directly practice with clients/patients/students at this time. We will continue to monitor the situation closely and consider additional options as service providers affected by COVID-19 announce their plans to reopen/finalize the school year.

ASHA certification standards require a CF experience to be a minimum of 36 weeks and 1,260 hours. There is a "work week" requirement that states at least 80% of a Clinical Fellow's major responsibilities during the CF experience must be spent in direct client/patient contact (e.g., assessment, evaluation, screening, treatment, clinical research activities, family/client consultations, recordkeeping, report writing, and/or counseling) related to the management process for individuals who exhibit communication and/or swallowing disabilities.

The CFCC has relaxed this work week requirement between March 16 – May 31, 2020*, to allow Clinical Fellows who are unable to be on site or provide services through telepractice to count hours and acquire weeks of experience in the ways below. These activities must be permissible by your employer, CF mentor, and/or state licensing laws. Clinical Fellows may still continue to count time spent in "other" activities such as professional development, as long as it does not exceed 20% of their current work week. For example, if a Clinical Fellow is able to work 20 hours per week in the ways below, an additional 4 hours may be spend in other activities.

Clinical Fellows in locations where telepractice and telesupervision is permitted

  • Clinical Fellows may utilize telepractice provided an appropriately credentialed speech-language pathologist (see Standard VII) is available to assist in a similar manner to the supervision/assistance that is provided when services are delivered face-to-face. In addition, (1) the Clinical Fellow, the supervisor/CF mentor, and the client/patient/student must all currently reside in the United States, and (2) the Clinical Fellow, the supervisor, and the CF mentor must be appropriately credentialed to provide services both in the state they reside and in the state(s) that they provide services.
  • Telesupervision may be used for direct, on-site, and in-person observations of Clinical Fellows by the CF mentor(s) for a segment of the CF experience that occurs between March 16, 2020, and May 31, 2020*. As a reminder, a minimum of six hours of direct observations are required per segment (one-third of the CF experience) and up to six hours may be completed in one day.

Clinical Fellows in locations or worksites that do not permit telepractice and telesupervision can acquire hours/weeks of experience by

  • completing report writing, notes, billing, IFSPs/IEPs, plans of care, etc.;
  • virtually consulting with allied health providers, teachers or Child Study Team members, and family/patients (CF mentors may observe these activities as "direct" observations);
  • planning and preparing testing schedules for the end-of-year testing;
  • preparing home programs and additional take-home packets for their clients/patients/students (CF mentors may consider the time working with the Clinical Fellow in preparing these home programs as "direct" observations); and/or
  • completing indirect observations with their CF mentor in the form of reviewing documentation/cases.

As a reminder, for the purposes of ASHA certification, Clinical Fellows have 48 months from the date their CF experience began to complete their experience. Your end date may be extended past your original expected end date.

Please keep in mind that all local, state, and federal regulations, and employer policies, must be followed at all times. This is an unprecedented and fluid circumstance. We know that everyone is doing their best continue client/patient/student care and that Clinical Fellows need to continue to increase their skills/readiness for independent practice. The CFCC understands the uniqueness of the situation; however, we have the responsibility to ensure that CF experiences are completed in a reasonable and responsible way to ensure Clinical Fellows are prepared for independent practice without sacrificing client/patient/student care.

In all cases, clinical educators, and CF mentors must meet the requirements as outlined in the 2020 certification standards. Please remember that all clinical educators, graduate students, Clinical Fellows, and CF mentors must ensure that telepractice and telesupervision are completed in accordance with HIPAA, FERPA, and prevailing local, state, and/or federal regulations.

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