Medicare Updates Definition of Speech-Language Pathologist in Its Benefit Policy Manual

Update: June 23, 2025

ASHA collaborates with other stakeholders [PDF] to urge CMS for clarity on Medicare Policy Manual update and to submit a follow up meeting request.

June 9, 2025

The Centers for Medicare & Medicaid Services (CMS) recently updated Chapter 15 of the Medicare Benefit Policy Manual [PDF] to revise the definition of a qualified speech-language pathologist (SLP) for Part B (outpatient) services. Although the manual was just updated, this change was originally finalized in the 2015 home health prospective payment system final rule and applies to services provided on or after January 1, 2015. The update aligns Medicare policy with federal law and ensures qualifications for SLPs are the same across all Part B (outpatient) practice settings.

Updated Definition

Federal regulations (42 CFR 484.115) and law (Section 1861(ll)(a)(4)(A) of the Social Security Act) define a speech-language pathologist as an individual who has a master's or doctoral degree in speech-language pathology, and who meets either of the following requirements:

1. Is licensed as a speech-language pathologist by the state in which the individual furnishes such services; or
2. In the case of an individual who furnishes services in a state which does not license speech-language pathologists:
   • Has successfully completed 350 clock hours of supervised clinical practicum (or is in the process of accumulating supervised clinical experience);
   • Performed not less than 9 months of supervised full-time speech-language pathology services after obtaining a master's or doctoral degree in speech-language pathology or a related field; and
   • Successfully completed a national examination in speech-language pathology approved by the Secretary.

This replaces the previous standard from 2009 (as outlined in Transmittal 106, Change Request 6381 [PDF]), which was the first year SLPs were allowed to independently enroll in and bill Medicare for outpatient services. At that time, not all states licensed SLPs. Therefore, Medicare needed a national qualification standard to serve as the basis to define a qualified SLP and, in part, relied on the standards set forth in the Certificate of Clinical Competence (CCC). Since then, all states now license SLPs (as of 2012).

Previously, the 2009 guidance defined a qualified SLP for program coverage purposes as an individual who meets one of the following requirements:

• The education and experience requirements for a Certificate of Clinical Competence in (speech-language pathology) granted by the American Speech-Language-Hearing Association; or
• Meets the educational requirements for certification and is in the process of accumulating the supervised experience required for certification.

Impact on Individuals Holding a Provisional License

Most states issue a modified form of licensure to new graduates—including clinical fellows (CFs)—while they complete their supervised clinical work experience needed to obtain a full license. Depending on the state, these may be called provisional, temporary, restricted, intern, interim, and even registration. For clarity, ASHA will refer to this licensure as a provisional license acknowledging it is called different things by different states.

• In every state but North Dakota, an individual with a provisional license must complete supervised post-graduate clinical training to become fully licensed.
• This training may also be used towards meeting requirements to apply for the CCC if the supervision and training required by the state are equivalent to the requirements for the CCC.

Since the policy update removed the reference to “meet[ing] the educational requirements for certification and… in the process of accumulating, the supervision experience required for certification,” it was important to clarify the status of all provisional licensees, including CFs, to ensure these individuals remain compliant with Medicare regulations. In follow-up communications to ASHA, CMS clarified that provisional licensure does not meet the definition of “licensed” for the purposes of Medicare provider enrollment. This means that an individual with a provisional license is not considered a qualified Medicare provider and:

• cannot enroll as a Medicare provider
• cannot bill Medicare for the services they provide

Impact on Employers Hiring Individuals with a Provisional License

This updated guidance raises questions for employers regarding hiring provisionally licensed SLPs (including CFs) because it disqualifies them for payment. Medicare’s updated definition does not provide a designation or recognition of provisional licensees such as CFs. As ASHA works to resolve this issue, it may be safest to follow Medicare student supervision standards to remain compliant. Employers should consider several points regarding this change:

1. Medicare standards only apply to Medicare. While other insurers (state Medicaid programs and private health plans) may adopt Medicare policies—they do not have to. Employers should check with other payers to see if they will a) cover services provided by provisional licensees, and b) under what circumstances—this is critically important to ensure compliance.
2. Medicare may cover services provided to Part A patients by provisional licensees in some facility settings. In facilities that bill Medicare under Part A—such as hospitals or skilled nursing facilities—students require general supervision. This means that a licensed SLP must be somewhere within the facility and available to assist if needed. The licensed SLP does not have to provide personal supervision (i.e., in the room, guiding and directing the services) as required under Part B. Therefore, in facilities who employ at least one licensed SLP who is working at the same time as a provisional licensee, the services can be provided by the provisional licensees to Medicare Part A patients and billed under the facility’s NPI. ASHA recognizes this is not a perfect solution, particularly for those patients who may transition between Part A and B services or for those in rural areas and/or in areas with staffing shortages, but it could provide an employment mechanism in some circumstances.
3. State licensure laws for scope of practice—provisional vs. full. The scope of practice (evaluation, diagnosis, treatment) for CFs and SLPs is the same whether an individual holds a provisional or a full license. The primary difference is the title of the license (e.g., provisional). In addition, for those who are pursuing their clinical fellowship, they need to comply with the supervision standards required to obtain the CCC and state licensure. Therefore, the varied licensure title is largely a distinction without difference and fails to acknowledge that provisional licensees have earned a master’s or doctoral degree and completed supervised clock hours of clinical practicum as required by Medicare and under most state laws.

What’s Next

ASHA is currently communicating with CMS. We are making the case for recognizing provisional licensees as qualified Medicare providers. A meeting with CMS is being scheduled to walk through the relevant federal and state legislative and regulatory history, explain why provisional licensure must be included in federal personnel qualifications for SLPs, and strongly advocate for their inclusion in Medicare.

Each employer should assess their risk and determine how to proceed accordingly, but conservatively, employers should apply Medicare student supervision standards to provisional licensees at this time. Key points to remember are:

• Under Part B (outpatient services), individuals with a provisional license should not provide services billed to Medicare without the same supervision as required for a student.
• Under Part A (hospitals, SNFs), individuals with a provisional license may provide services billable under the facility’s NPI only if a licensed SLP is on-site and available to assist if needed.

We will continue to update our members as details become available.

Questions?

Please contact reimbursement@asha.org. And, share your feedback in ASHA's Federal and State Policy Impact Member Feedback Form.