Supervision of Assistants, Graduate Students, and Clinical Fellows: Billing and Payment Compliance


Supervision requirements of assistants, graduate students, and clinical fellows can vary widely by state, setting, and payer. It is important to consider all applicable requirements to ensure that you are billing appropriately.  

State law dictates eligibility requirements for practicing in the state, and regulations may be different depending on your setting. For example, states may have different requirements for clinicians working in schools than those working in health care or other settings. It is important to check with your state for practice and licensing requirements.

ASHA develops its own supervision standards to meet minimum standards for certification, but the final authority on billing and payment requirements is the patient’s insurance plan (payer), in compliance with state law. Requirements can vary even within a single payer—depending on the provider type, insurance plan, and setting—so it’s best to check with the patient’s plan directly. Some payers may publish their policies publicly online, whereas others will require a provider sign-in for access. Commercial plans may provide more information to a patient on their insurance plan’s coverage, but providers should be able to directly ask about enrollment requirements and basic billing information. It’s critical to identify the requirements for the provider type, setting, and insurance plan being billed.

Billing and Payment Compliance Considerations for:


Please contact ASHA’s health care policy team at for questions related to supervision requirements to maintain billing and payment compliance.

ASHA Corporate Partners