Q&A: 2025 Medicare Part B Updates to SLP Provider Requirements

Information for Provisional Licensees, CFs, and Employers

The Centers for Medicare & Medicaid Services (CMS) has updated its definition of a qualified speech-language pathologist (SLP) in Chapter 15 of the Medicare Benefit Policy Manual (MBPM) [PDF] for Medicare Part B (outpatient) billing.

As clarified by CMS in direct communication with ASHA, the term licensed must be interpreted literally. It does not include provisional, temporary, or limited licenses—unless explicitly stated. Therefore, provisional licensees, including clinical fellows (CFs), are not eligible to bill Medicare Part B, as they do not hold a full state license. This also applies to outpatient services delivered in inpatient settings (e.g., hospitals, skilled nursing facilities) and home health.

See ASHA Advocacy News: Medicare Updates Definition of Speech-Language Pathologist in Its Benefit Policy Manual for more information.

What Changed, and Why Is It Significant?

Background

• 2008: Congress changed the Social Security Act so that SLPs could enroll in and independently bill Medicare for the first time.
• 2009: Medicare (CMS) defined a “qualified SLP” as someone who:

1. 1. Had completed the education and experience needed for ASHA’s Certificate of Clinical Competence (CCC), or
   2. Had finished their education and was in the process of completing their supervised clinical fellowship to earn the CCC.

At that time, not all states licensed SLPs, so the CCC was used as the national standard.

• 2012: All states provided full licensure for SLPs.

Changes in the 2025 MBPM Update

The 2025 update to the MBPM included significant changes:

1. Removed the CCC as part of the personnel qualifications.
2. Eliminated the allowance for those practicing during their supervised clinical experience by removing the following language: “Meets the educational requirements for certification and is in the process of accumulating the supervised experience required for certification.”
3. Added state licensure to the definition for the first time. Among other requirements, the equivalency to the state license in states that do not license SLPs is having “performed at least 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.” This definition clearly does not include SLPs who are actively in their supervised clinical experience, which falls under provisional licensure in most states.
4. Changed the standards for states without licensure, which offers an alternative option for qualification if a state decides to eliminate professional licensure in the future.

What Was the Timeline for the Policy Change?

• 2015: CMS revised the definition of a “qualified SLP” in the 2015 home health prospective payment system final rule but did not broadly publicize the change or engage in provider education. Chapter 15 of the MBPM and local coverage determinations issued by Medicare Administrative Contractors (MACs) retained the 2009 language.
• May 23, 2025: CMS published MLN article MM13922 [PDF], dated April 18, 2025, with the updated definition.
• May 29, 2025: CMS shared this information in a provider email. ASHA began analysis of the update and consulted CMS regarding the definition of state license.
• June 4, 2025: CMS indicated to ASHA via email that “provisional” licensure does not meet the definition of “license.”
• June 9, 2025: ASHA notified members, National NSSLHA members, students, and CFs.

What Clarification Did CMS Provide to ASHA?

ASHA reached out to CMS staff upon review of the provider email issued on May 29. CMS staff directly clarified to ASHA via email stating that they can’t “interpret the term ‘licensed’ to mean anything other than its plain meaning; and for it to mean a temporary, limited, or provisional license, it would need to state that specifically.” Therefore, ASHA concluded that provisional licensees—including CFs—are not eligible to bill Medicare for Part B services.

Why Did ASHA Share Information That Wasn’t Officially Published By CMS?

ASHA made the decision to share CMS’ clarification regarding the definition of a state license after careful consideration of several important factors.

Ensuring Members Are Fully Informed

We believe it’s essential that our members have access to all relevant information available. Even though this CMS clarification wasn’t in a formal policy update, it carried weight because:

• It came directly from CMS officials, and it involved critical regulatory interpretation.
• It affects members and their employers who need to know this information so they can evaluate their compliance with Medicare rules and/or take appropriate steps to assess and mitigate their risks.

We understand the stress and uncertainty this has caused, but transparency is critical to helping our members and their employers make informed decisions.

Responding to Ongoing Enrollment Issues

Members and employers had already been experiencing challenges enrolling provisional licensees, including CFs, with some MACs, TRICARE, and a growing number of private insurers. These challenges included:

• Delays or denials in provider enrollment applications for provisional licensees.
• De-enrollment of providers already enrolled who held provisional licenses.

In nearly every case, these actions were taken because the provider held a provisional, rather than full, license. These problems signaled a growing trend and contributed to ASHA's decision to contact CMS for clarification.

Urgency to Act Due to Policy Implementation Timeline

Although the updated language in the MBPM has been in effect since January 1, 2025, CMS did not issue widespread notice or engage in provider education about the change. Once ASHA became aware of the updates, we felt a strong responsibility to fill this information gap. By alerting our members and employers now, we hope to give you the necessary information to review the 2025 MBPM updates and determine their impact on your unique circumstances.

What Is ASHA Doing to Help?

ASHA fully understands the adverse impact this CMS update has on provisional licensees and their employers. We know you are anxious and want guidance on what to do.

We are:

• Actively advocating for policy change with CMS to officially include provisional licensees in the definition of a qualified SLP.
• Meeting with CMS to explain the significant impact of their interpretation of “license,” walk through the legislative and regulatory history of SLPs as Medicare providers, and advocate for inclusion of provisional licensure.
• Mobilizing stakeholders—including members like you—in our advocacy efforts. ASHA has also been communicating and collaborating with other associations and health systems to collectively advocate to CMS about the impact of the changes.
• Petition Drive: Sign this petition by June 25 requesting CMS revise its interpretation of “license” to include provisional licenses.
• Sharing updates through emails, the ASHA Advocate, and on the ASHA advocacy webpage.

Frequently Asked Questions

Does this affect other insurance besides Medicare?

The policy outlined by CMS only applies to Medicare Part B. However, ASHA is aware that other payers, such as TRICARE and some MACs, have independently made a similar decision to deny enrollment for provisional licensees like CFs. Each state Medicaid agency and its contracted managed care entities handle CF billing differently. Coverage of CF services is highly variable among private insurers, and more insurers may follow Medicare’s lead. It’s important to check directly with individual payers regarding their provider qualification requirements. ASHA will continue to monitor and address these issues with Medicaid and other payers.

Will this impact Medicare Advantage patients as well as patients on traditional Medicare?

This is not clear, so ASHA is asking CMS for clarification. In the meantime, you should check directly with the Medicare Advantage plan.

How does this apply to inpatient settings like acute care hospitals that use bundled billing?

It is important to distinguish between the supervision requirements established by ASHA for earning the Certificate of Clinical Competence (the CCC) and those required for payment by insurance companies. The ASHA website has full details on what is required for the CCC, including 36 hours of supervision from a mentor who also has their CCC.

Insurance companies are able to determine their own requirements for billing, including the personnel qualifications, whose NPI appears on the claim, and the level of supervision required for students and provisional licensees. Medicare requires unlicensed individuals, such as students, to be supervised by a licensed SLP. This individual may or may not be the CF’s mentor. Under the interpretation CMS staff provided to ASHA, provisional licensure does not meet the definition of a license, so it would require an additional level of supervision by a licensed SLP for payment purposes. The level of supervision required varies based on whether the services are billed under Part A or Part B as described on the ASHA website.

If Medicare continues to consider CFs with provisional or temporary licensure as students, then they cannot enroll and bill Medicare directly for services they provide. They could engage in service delivery with the required level of supervision and even help draft documentation, but that documentation would need to be fully reviewed and signed by the supervising SLP clinician. Documentation should also indicate the level of supervision provided. For more on student billing requirements, see Supervision of Graduate Students: Billing and Payment Compliance.

If the rule changed in 2015, why are CFs being affected now?

The rule was changed in 2015, but CMS is only now interpreting it and adding it to the Medicare Benefit Policy Manual [PDF] for enforcement .

Will CMS ask for recoup payments for services provided by CFs or those with a provisional license?

CMS has not stated whether it will engage in post-payment audits based on a retroactive application of an updated policy. ASHA is actively seeking clarification on this issue and will strongly advocate against post-payment audits and recoupment if necessary.

Can provisional licensees and CFs work in medical settings that bill Medicare?

If a facility bills Medicare Part B, CFs and provisional licensees are not currently allowed to provide services to Medicare beneficiaries under the latest CMS guidance. ASHA is actively advocating for this policy to change.

I'm currently a CF in a medical setting. What does this mean for me?

Unfortunately, under current CMS rules, you may not be compliant with Medicare regulations. ASHA understands you are in a difficult position, and we are actively advocating for CMS to change its interpretation of licensure. Please clarify with your employer directly on how they choose to interpret and apply the newest CMS guidance.

Because of CMS’ interpretation of licensure, CFs require personal supervision (over-the-shoulder supervision). Practicing without this level of supervision would put your employer at risk of an audit. A licensed SLP would need to be present in the room and able to direct the service, then services could be billed under the National Provider Identifier (NPI) of the supervising SLP. ASHA advises having an immediate conversation with your employer.

I have a provisional license—isn't that enough?

CMS has clarified that only full or permanent licenses count. Temporary, provisional, or limited licenses are not currently recognized. ASHA is actively advocating for this policy to be reversed.

Does the CF's assigned supervisor need to be on site or can another licensed SLP provide the required supervision?

It is important to distinguish between what is required for the ASHA CCCs and what is required for payment. For Medicare payment, any licensed, on-site SLP can provide the required level of supervision for payment purposes; it does not need to be the CF’s assigned fellowship mentor.

Can I just bill under my supervisor's NPI?

When billing Part B, documentation should include the name, signature, and NPI of the supervising clinician. All documentation should also include information on who rendered the service and the level of supervision provided. Other payer requirements (Medicaid, private plans) differ, so it is best to check with them directly for information. By restricting coverage to fully licensed SLPs and excluding those with a provisional license, Medicare has essentially classified CFs as “students,” so they cannot sign their own documentation. Any CF providing services to a patient on Part B must receive 100% direct supervision and all part B claims must be “signed” by the supervisor and include the supervisor’s NPI.

Does telesupervision “count”?

At this time, Medicare does not allow for a licensed therapist (e.g., an SLP) to telesupervise a student. Because CMS has clarified that a “provisional” license does not meet the definition of a license, CFs and students must be supervised in person. Find more details about the Medicare student supervision standards.

Will this impact grad student practicum placements?

Most likely, yes. CFs may now be assigned patients previously available to students, creating a trickle-down effect in medical placements.

Everyone is giving me a different interpretation. How do I know which one to follow?

As a membership organization, ASHA takes its commitment to serving its members seriously, including the mitigation of compliance risk. We share a common goal with other stakeholders of ensuring SLPs remain employed so they can continue to do the work they love, employers can remain in business, and Medicare beneficiaries maintain access to care. There is common agreement that Section 1861(ll)(a)(4)(A) of the Social Security Act should include both provisionally and fully licensed SLPs.

This situation is unique given the policy change occurred in 2015 yet implementation guidance was not released until 2025. The implementation guidance stated in MLN article MM13922 that there is no new policy. This is correct; CMS finalized the definition of a qualified SLP in 2015, and this MLN article reflects the 2015 standard. From CMS’ perspective, the content of MLN article MM13922 is not a policy change. What it fails to account for is that provisional licensees have already been rejected by MACs as qualified professionals and that in the absence of licensure, the “backup” personnel qualification includes a requirement for having completed the nine-month supervised experience, which most provisional licensees have not done.

ASHA received direct, written communication from CMS that stated that provisional licensure did not meet this standard. ASHA is forcefully pushing back against this interpretation. But in the interim, ASHA had an obligation to mitigate our members’—and their employers’—compliance risk. We’ve provided, and will continue to provide, all the information we have in a timely fashion. ASHA has consistently stated that decisions on how to proceed must include an understanding of Medicare guidance in conjunction with guidance from your employer.

Can my state remove provisional licensure?

ASHA does not advocate for the removal of provisional licensure or the supervised professional experience (SPE). The SPE is a widely accepted method for new professionals to transition from their academic studies to independent practice. It provides a crucial period of mentorship and support, ensuring that new SLPs gain real-world experience under the guidance of seasoned professionals. This kind of postgraduate experience isn't unique to SLPs; many other health care professions also require a supervised period before full licensure.

Additionally, eliminating the SPE would have significant negative consequences, particularly for SLPs who want to practice across state lines:

• Interstate Practice Hurdles: If some states remove the SPE requirement while others keep it, existing reciprocity agreements that simplify practicing in multiple states would no longer apply. This means an SLP licensed in a state without an SPE requirement might find it harder, if not impossible, to get licensed in a state that still requires it.
• Interstate Compact Ineligibility: The Audiology & Speech-Language Pathology Interstate Compact (ASLP-IC) specifically requires states to have the SPE as part of their licensing provisions. The ASLP-IC is set to become operational this year, making it easier for SLPs to practice in participating states. If a state removes its SPE requirement, it would no longer be eligible to participate in the ASLP-IC, cutting off a valuable pathway for its licensees to work in other ASLP-IC member states.

Even if a particular state wanted to remove the SPE, making such a change would be a lengthy and complex process. It would require states to go through their full legislative procedures to amend their licensing laws. Most state legislatures have already concluded their sessions for the year, meaning any such changes would likely be delayed until 2026 or even later. As noted above, ASHA maintains that the solution to this challenge is CMS compliance with Section 1861 (ll)(a)(4)(a) that holds the regulatory mechanism selected by the state demonstrates the qualification of the SLP.

Can we change the ASLP-IC requirements?

Interstate compacts like the ASLP-IC function as both state law and contractual agreements between participating states. This dual nature makes them incredibly robust but also challenging to modify.

The ASLP-IC Commission currently comprises 36 member states and one territory. Any proposed changes to the compact's fundamental requirements would first need to be unanimously agreed upon by all the members. If the commission reached such an agreement, every state would be required to pass new legislation incorporating those changes into the existing law. This is a time-consuming and politically sensitive endeavor, susceptible to delays, opposition, or even outright rejection in any single state.

The ASLP-IC is currently focused on becoming fully operational, with the CompactConnect data system expected to launch in fall 2025. Introducing substantial changes to the core requirements now would effectively reset much of this progress. The time spent debating and enacting new legislation across all member states would inevitably postpone the compact from going live for several additional years, undermining the very purpose of establishing a streamlined interstate practice framework.

Do other professions have provisional licensure?

Yes, many health care professions require some form of provisional or temporary license for individuals to gain supervised postgraduate experience before they can obtain a full, unrestricted license. This is a common mechanism to ensure new graduates or those with limited experience practice safely and develop their skills under the guidance of experienced professionals.

Questions?

Contact reimbursement@asha.org.

(Please note response times may be delayed due to volume.)