Provisional Licensure for CFs Authorized in Tennessee and Hawaii

Regulations & Implementation to Follow

June 20, 2019

Tennessee passed House Bill 339 on May 15, 2019, authorizing clinical fellows (CFs) to obtain a provisional license to practice speech-language pathology. Although the bill has been signed into law, regulations have yet to be established. Hawaii enacted similar legislation through passage of House Bill 252 on April 30, 2019, but the bill is still awaiting the Governor’s approval. Most payers (Medicare, Medicaid, and commercial plans) will not move forward with changes to its qualified provider requirements until the licenses are issued. Once licenses are issued, there will be more clarity on CF billing. Please check with payers/insurers to ensure compliance with billing requirements for services performed by CFs.


Licensure is required for Medicare reimbursement. Medicare law recognizes unlicensed CFs as students that require 100% supervision by a qualified Medicare provider for services provided to Medicare beneficiaries. ASHA has worked closely with state associations to advocate for provisional licensure for CFs across the country.


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