Many clinicians are serving clients through telepractice due to the COVID-19 pandemic. ASHA developed Telepractice Resources During COVID-19 to provide guidance on service delivery. As the pandemic continues, questions have arisen regarding interstate and international practice requirements. ASHA addresses these topics below.
Providers should be aware of the licensing regulations in the state where they are physically located and where the client is physically located at the time of the service delivery. This guidance is for all services within the Scope of Practice in Speech-Language Pathology, including services billed through insurance, private pay, or pro bono services. During the COVID-19 pandemic, many states have emergency/temporary provisions in their statutes or regulations that allow members to practice across state lines for a defined period of time. ASHA’s COVID-19: Tracking of State Laws and Regulations for Telepractice and Licensure Policy [PDF] provides a summary of provisions and policy changes for each state. About half of state governors have issued executive orders allowing for practice across state lines. In one third of those states, members may provide services to temporary residents but must also notify the licensure board. In the remaining states, members may provide services without notifying the board.
If the client is temporarily located in a state where they do not reside at the time of service, ASHA suggests contacting that state’s licensure board to determine whether the board will allow services to be provided within their state if an emergency provision is not in place. Members are encouraged to indicate that the client is a permanent resident of the state where you are credentialed and that there is an existing client/provider relationship.
ASHA’s State-by-State page includes contact information for each state’s licensure board.
If you are temporarily living in or visiting a state where you are not licensed but are planning to deliver services to clients who reside in a state where you are licensed, ASHA suggests that you notify the licensure board in the state where you are temporarily residing of your intention to serve clients who are permanent residents of the state where you hold an active license.
Consulting with clients and/or coaching families in person or via telecommunications is a clinical service; it is just a different service delivery approach from direct intervention. ASHA’s Scope of Practice for the profession of speech-language pathology includes elective services (e.g., accent modification), prevention, wellness, advocacy, outreach, and education as part of a speech-language pathologist’s (SLP’s) practice domains in addition to consultation, assessment, and treatment. The ASHA Code of Ethics indicates that “Individuals shall not misrepresent their credentials, competence, education, training, experience, and scholarly contributions.” When providing these services, ASHA recommends consulting with the state licensing board where the client is located if an emergency provision is not in place.
If you have a client who is living in another country, then ASHA suggests contacting the professional society or regulatory body in the country where you wish to practice for guidance. ASHA maintains a list of Audiology and Speech-Language Pathology Associations Outside of the United States, which includes contact information. If there is not an association in that country, or for additional information, ASHA suggests contacting the U.S. Embassy in that country or the Ministry of Health or Ministry of Education. When providing services outside of the United States, ASHA-certified audiologists and SLPs still must adhere to the following standards:
ASHA supports the use of telepractice and welcomes the flexibility that states are providing during the COVID-19 pandemic to promote safety for both providers and clients. Ongoing advocacy for flexibility to deliver services via telepractice beyond the pandemic will continue as well as efforts for Medicaid and private insurers to cover telepractice services for clients permanently.
Through collaboration with the Council of State Governments, ASHA is advocating for states to adopt legislation for the Audiology and Speech-Language Pathology Interstate Compact, which would allow audiologists and SLPs to obtain a privilege to provide telepractice across state lines in participating states. ASHA has also developed model language that state associations and state licensure boards can use to work with state legislators in order to advocate for extended flexibility for interstate practice; see ASHA’s Model Language for Interstate Telepractice [PDF].